SEC Comment Letter for Circle of Wealth Fund III LLC (CIK 0001762825) — Apr 7, 2020
Circle of Wealth Fund III LLC (CIK 0001762825)
Date: April 7, 2020 · CIK: 0001762825 · Accession: 0000000000-20-002997
AI Filing Summary & Sentiment
File numbers found in text: 024-10948
Letter
April 6, 2020 Lee Aaron Arnold Chief Executive Officer of Secured Investment Corp. Circle of Wealth Fund III LLC 701 East Front Street, 2nd Floor Coeur D'Alene, ID 83814 Re:Circle of Wealth Fund III LLC Offering Statement on Form 1-A Post-Qualification Amendment No. 3 Filed March 30, 2020 File No. 024-10948 Dear Mr. Arnold: We have reviewed your amendment and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your offering statement and the information you provide in response to this comment, we may have additional comments. Post-qualification Amendment to Form 1-A filed on March 30, 2020 Acceptance, page 9 1.We note your response to comment 1 and that you continue to disclose that the email will include an outline of the offer. Please revise your disclosure to state that the email about the rescission offer will include a hyperlink to the offering circular. We will consider qualifying your offering statement at your request. If a participant in your offering is required to clear its compensation arrangements with FINRA, please have FINRA advise us that it has no objections to the compensation arrangements prior to qualification. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameLee Aaron Arnold Comapany NameCircle of Wealth Fund III LLC April 6, 2020 Page 2 FirstName LastName Lee Aaron Arnold Circle of Wealth Fund III LLC April 6, 2020 Page 2 You may contact Jonathan Burr at 202-551-5833 or Pamela Long at 202-551-3765 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
April 6, 2020
Lee Aaron Arnold
Chief Executive Officer of Secured Investment Corp.
Circle of Wealth Fund III LLC
701 East Front Street, 2nd Floor
Coeur D'Alene, ID 83814
Re:Circle of Wealth Fund III LLC
Offering Statement on Form 1-A
Post-Qualification Amendment No. 3
Filed March 30, 2020
File No. 024-10948
Dear Mr. Arnold:
We have reviewed your amendment and have the following comment. In our comment,
we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response. After reviewing any amendment to your offering statement and the information you
provide in response to this comment, we may have additional comments.
Post-qualification Amendment to Form 1-A filed on March 30, 2020
Acceptance, page 9
1.We note your response to comment 1 and that you continue to disclose that the email will
include an outline of the offer. Please revise your disclosure to state that the email about
the rescission offer will include a hyperlink to the offering circular.
We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameLee Aaron Arnold
Comapany NameCircle of Wealth Fund III LLC
April 6, 2020 Page 2
FirstName LastName
Lee Aaron Arnold
Circle of Wealth Fund III LLC
April 6, 2020
Page 2
You may contact Jonathan Burr at 202-551-5833 or Pamela Long at 202-551-3765 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction