SEC Company Response from Circle of Wealth Fund III LLC (CIK 0001762825) — Apr 8, 2020
Circle of Wealth Fund III LLC (CIK 0001762825)
Date: April 8, 2020 · CIK: 0001762825 · Accession: 0001731122-20-000358
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File numbers found in text: 024-10948
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CORRESP
1
filename1.htm
Circle of Wealth Fund III LLC
701 E. Front Avenue, Floor 2
Coeur D’Alene, ID 83814
April 8, 2020
Mr. Jonathan Burr and Ms. Pamela Long
Division of Corporate Finance - Office of Real
Estate & Commodities
100 F Street, N.E.
Washington D.C. 20549
Re:
Circle of Wealth Fund III LLC (the “Company”)
Offering Statement on Form 1-A
Post Qualification Amendment No.1
Filed on February 13, 2020
File No. 024-10948
Dear Mr. Burr and Ms. Long:
On behalf of the Company, I respectfully request
that the qualification date of the offering statement be accelerated and that the offering statement be declared qualified on April
10, 2020, or as soon thereafter as is reasonably practicable.
In making this request, the Company acknowledges
the following:
·
should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing qualified, it does not foreclose the Commission from taking any action with respect to the filing;
·
the action of the Commission or the staff, acting pursuant to delegated authority, to declare the filing qualified does not relieve the Company from its full responsibility for the adequacy and accuracy of disclosure in the filing; and
·
the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.
Sincerely,
/s/ Lee Arnold
Lee Arnold
President and CEO of Secured Investment Corp.,
Manager
Circle of Wealth Fund III LLC