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SEC Comment Letter for LB 1 LLC (CIK 0001779420) — Aug 5, 2020

LB 1 LLC (CIK 0001779420)
Date: Aug. 5, 2020 · CIK: 0001779420 · Accession: 0000000000-20-007136

AI Filing Summary & Sentiment

File numbers found in text: 024-11147

Date
August 4, 2020
Author
Not clearly detected
Form
UPLOAD
Company
LB 1 LLC (CIK 0001779420)

Letter

United States securities and exchange commission logo August 4, 2020 Amed Hazel Manager LB 1 LLC 818 Natchez Valley Trace Grayson, GA 30017 Re:LB 1 LLC Amendment No. 3 to Offering Statement on Form 1-A Filed July 22, 2020 File No. 024-11147 Dear Mr. Hazel: We have reviewed your amended offering statement 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 this letter by amending your offering statement and providing the requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 22, 2020 letter. Amendment No. 3 to Offering Statement on Form 1-A filed July 22, 2020 Description of Securities Offered, page 24 1.We note your response to comment 3. Please disclose the interest rate table in the description of securities offered, disclose the principal terms of the securities, and clarify the extent to which you are offering 4 separate notes depending on the amount invested and duration. Additionally, we note the disclosure that you intend to "produce attractive risk adjusted returns by purchasing distressed loans and also by making real estate backed loans. . .." Please tell us whether the notes you are offering are linked to underlying securities.

FirstName LastNameAmed Hazel Comapany NameLB 1 LLC August 4, 2020 Page 2 FirstName LastName Amed Hazel LB 1 LLC August 4, 2020 Page 2 Sponsor's Experience, page 28 2.We note your response to comment 2 and the revised disclosure on page 28. Please revise to •disclose which programs were "public and nonpublic" and the duration of the programs, including whether they were completed, •clarify whether the programs involved "solely Mortgage Backed Securities" per paragraph (a) versus the commercial and residential "properties purchased" discussed in paragraphs (d), (f), (g) and (h), •quantify the approximate amount of "success" fees, commissions, advisory and other remuneration, Additionally, please revise to disclose if the sponsor has experienced any material adverse business developments or conditions and to ensure that the information presented about the sponsor's past experience and performance is balanced. You may contact Jorge Bonilla at 202-551-3414 or Robert Telewicz at 202-551-3438 if you have questions regarding comments on the financial statements and related matters. Please contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction

Show Raw Text
United States securities and exchange commission logo
August 4, 2020
Amed Hazel
Manager
LB 1 LLC
818 Natchez Valley Trace
Grayson, GA 30017
Re:LB 1 LLC
Amendment No. 3 to
Offering Statement on Form 1-A
Filed July 22, 2020
File No. 024-11147
Dear Mr. Hazel:
            We have reviewed your amended offering statement 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 this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our June 22, 2020 letter.
Amendment No. 3 to Offering Statement on Form 1-A filed July 22, 2020
Description of Securities Offered, page 24
1.We note your response to comment 3.  Please disclose the interest rate table in the
description of securities offered, disclose the principal terms of the securities, and clarify
the extent to which you are offering 4 separate notes depending on the amount invested
and duration.  Additionally, we note the disclosure that you intend to "produce attractive
risk adjusted returns by purchasing distressed loans and also by making real estate backed
loans. . .."  Please tell us whether the notes you are offering are linked to underlying
securities.

 FirstName LastNameAmed Hazel
 Comapany NameLB 1 LLC
 August 4, 2020 Page 2
 FirstName LastName
Amed Hazel
LB 1 LLC
August 4, 2020
Page 2
Sponsor's Experience, page 28
2.We note your response to comment 2 and the revised disclosure on page 28.  Please revise
to
•disclose which programs were "public and nonpublic" and the duration of the
programs, including whether they were completed,
•clarify whether the programs involved "solely Mortgage Backed Securities" per
paragraph (a) versus the commercial and residential "properties purchased" discussed
in paragraphs (d), (f), (g) and (h),
•quantify the approximate amount of "success" fees, commissions, advisory and other
remuneration,
Additionally, please revise to disclose if the sponsor has experienced any material adverse
business developments or conditions and to ensure that the information presented about
the sponsor's past experience and performance is balanced.
            You may contact Jorge Bonilla at 202-551-3414 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction