SEC Comment Letter 0000000000-23-013647 to Beneficient (BENF)
Beneficient
Date: Dec. 14, 2023 · CIK: 0001775734 · Accession: 0000000000-23-013647
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-275174
Letter
United States securities and exchange commission logo December 14, 2023 Brad K. Heppner Chief Executive Officer Beneficient 325 North St. Paul Street, Suite 4850 Dallas, TX 75201 Re:Beneficient Amendment No. 1 to Registration Statement on Form S-1 Filed December 4, 2023 File No. 333-275174 Dear Brad K. Heppner: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a 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 registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our November 7, 2023 letter. Amendment No. 1 to the Registration Statement on Form S-1 filed December 5, 2023 Management's Discussion and Analysis Liquidity and Capital Resources, page 162 1.We note your response to comment 5 and reissue in part. Please revise your disclosure to clarify whether the Credit and Guarantee Agreement with HH-BDH impacts your ability to meet your expected funding needs.
FirstName LastNameBrad K. Heppner Comapany NameBeneficient December 14, 2023 Page 2 FirstName LastName Brad K. Heppner Beneficient December 14, 2023 Page 2 Please contact Robert Arzonetti at 202-551-8819 or Christian Windsor at 202-551-3419 with any other questions. Sincerely, Division of Corporation Finance Office of Finance cc: Matthew L. Fry, Esq.
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United States securities and exchange commission logo
December 14, 2023
Brad K. Heppner
Chief Executive Officer
Beneficient
325 North St. Paul Street, Suite 4850
Dallas, TX 75201
Re:Beneficient
Amendment No. 1 to Registration Statement on Form S-1
Filed December 4, 2023
File No. 333-275174
Dear Brad K. Heppner:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a 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 registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our November 7, 2023 letter.
Amendment No. 1 to the Registration Statement on Form S-1 filed December 5, 2023
Management's Discussion and Analysis
Liquidity and Capital Resources, page 162
1.We note your response to comment 5 and reissue in part. Please revise your disclosure to
clarify whether the Credit and Guarantee Agreement with HH-BDH impacts your ability
to meet your expected funding needs.
FirstName LastNameBrad K. Heppner
Comapany NameBeneficient
December 14, 2023 Page 2
FirstName LastName
Brad K. Heppner
Beneficient
December 14, 2023
Page 2
Please contact Robert Arzonetti at 202-551-8819 or Christian Windsor at 202-551-3419
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Matthew L. Fry, Esq.