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
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File numbers found in text: 024-11147
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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