SEC Comment Letter for Harbor Custom Development, Inc. (CIK 0001784567) — May 11, 2020
Harbor Custom Development, Inc. (CIK 0001784567)
Date: May 11, 2020 · CIK: 0001784567 · Accession: 0000000000-20-004112
AI Filing Summary & Sentiment
File numbers found in text: 333-237507
Letter
United States securities and exchange commission logo May 8, 2020 Sterling Griffin Chief Executive Officer and President Harbor Custom Development, Inc. 11505 Burnham Dr., Suite 301 Gig Harbor, Washington 98332 Re:Harbor Custom Development, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed April 28, 2020 File No. 333-237507 Dear Mr. Griffin: We have reviewed your amended registration 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 registration 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 registration 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 April 15, 2020 letter. Amendment No. 1 to Form S-1 Filed April 28, 2020 General 1.Please ensure that your filing discloses all information currently represented by blanks, except information that Rule 430A permits you to exclude. Also file all required exhibits to your registration statement. Summary Financial Data Other Financial Data, page 6 2.We note your response to prior comment 2 and your revised disclosure to the Other Financial Data table. However, we note your discussion of EBITDA margin on page 49. Please re-label the measure to more appropriately characterize the non-GAAP measure
FirstName LastNameSterling Griffin Comapany NameHarbor Custom Development, Inc. May 8, 2020 Page 2 FirstName LastName Sterling Griffin Harbor Custom Development, Inc. May 8, 2020 Page 2 or remove such disclosure for consistency. You may contact Isaac Esquivel at 202-551-3395 or Wilson Lee at 202-551-3468 if you have questions regarding comments on the financial statements and related matters. Please contact Ruairi Regan at 202-551-3269 or David Link at 202-551-3356 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Lynne Bolduc, Esq.
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United States securities and exchange commission logo
May 8, 2020
Sterling Griffin
Chief Executive Officer and President
Harbor Custom Development, Inc.
11505 Burnham Dr., Suite 301
Gig Harbor, Washington 98332
Re:Harbor Custom Development, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed April 28, 2020
File No. 333-237507
Dear Mr. Griffin:
We have reviewed your amended registration 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 registration 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 registration 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 April 15, 2020 letter.
Amendment No. 1 to Form S-1 Filed April 28, 2020
General
1.Please ensure that your filing discloses all information currently represented by blanks,
except information that Rule 430A permits you to exclude. Also file all required exhibits
to your registration statement.
Summary Financial Data
Other Financial Data, page 6
2.We note your response to prior comment 2 and your revised disclosure to the Other
Financial Data table. However, we note your discussion of EBITDA margin on page
49. Please re-label the measure to more appropriately characterize the non-GAAP measure
FirstName LastNameSterling Griffin
Comapany NameHarbor Custom Development, Inc.
May 8, 2020 Page 2
FirstName LastName
Sterling Griffin
Harbor Custom Development, Inc.
May 8, 2020
Page 2
or remove such disclosure for consistency.
You may contact Isaac Esquivel at 202-551-3395 or Wilson Lee at 202-551-3468 if you
have questions regarding comments on the financial statements and related matters. Please
contact Ruairi Regan at 202-551-3269 or David Link at 202-551-3356 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Lynne Bolduc, Esq.