SEC Comment Letter 0000000000-23-008944 to CIM Opportunity Zone Fund, L.P. (CIK 0001765107)
CIM Opportunity Zone Fund, L.P. (CIK 0001765107)
Date: Aug. 16, 2023 · CIK: 0001765107 · Accession: 0000000000-23-008944
AI Filing Summary & Sentiment
File numbers found in text: 000-56544
Letter
United States securities and exchange commission logo August 16, 2023 David Thompson Chief Financial Officer CIM Opportunity Zone Fund, L.P. 4700 Wilshire Boulevard Los Angeles, CA 90010 Re:CIM Opportunity Zone Fund, L.P. Amendment No. 2 to Registration Statement on Form 10 Filed July 28, 2023 File No. 000-56544 Dear David Thompson: We have reviewed your amended filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 11, 2023 letter. Amendment No. 2 to Registration Statement on Form 10 filed July 28, 2023 Certain Relationships and Related Transactions, page 61 1.We reissue comment 6. In order to explain how the incentive and management fees are calculated, please quantify the factors used in the formulas and disclose how these factors were determined for the year ended December 31, 2022.
FirstName LastNameDavid Thompson Comapany NameCIM Opportunity Zone Fund, L.P. August 16, 2023 Page 2 FirstName LastName David Thompson CIM Opportunity Zone Fund, L.P. August 16, 2023 Page 2 2. Summary of Accounting Policies Basis of Presentation, page F-9 2.We continue to evaluate your responses to comments 9 and 10 and may have additional comment. You may contact Ameen Hamady at 202-551-3891 or Robert Telewicz at 202-551-3438 if you have questions regarding comments on the financial statements and related matters. Please contact Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202- 551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Raphael M. Russo, Esq.
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United States securities and exchange commission logo
August 16, 2023
David Thompson
Chief Financial Officer
CIM Opportunity Zone Fund, L.P.
4700 Wilshire Boulevard
Los Angeles, CA 90010
Re:CIM Opportunity Zone Fund, L.P.
Amendment No. 2 to Registration Statement on Form 10
Filed July 28, 2023
File No. 000-56544
Dear David Thompson:
We have reviewed your amended filing and have the following comments. In some of
our comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments. Unless we note otherwise, our references to
prior comments are to comments in our July 11, 2023 letter.
Amendment No. 2 to Registration Statement on Form 10 filed July 28, 2023
Certain Relationships and Related Transactions, page 61
1.We reissue comment 6. In order to explain how the incentive and management fees are
calculated, please quantify the factors used in the formulas and disclose how these factors
were determined for the year ended December 31, 2022.
FirstName LastNameDavid Thompson
Comapany NameCIM Opportunity Zone Fund, L.P.
August 16, 2023 Page 2
FirstName LastName
David Thompson
CIM Opportunity Zone Fund, L.P.
August 16, 2023
Page 2
2. Summary of Accounting Policies
Basis of Presentation, page F-9
2.We continue to evaluate your responses to comments 9 and 10 and may have additional
comment.
You may contact Ameen Hamady at 202-551-3891 or Robert Telewicz at 202-551-3438
if you have questions regarding comments on the financial statements and related
matters. Please contact Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202-
551-3713 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Raphael M. Russo, Esq.