SEC Comment Letter 0000000000-23-013853 to Harbor Custom Development, Inc. (CIK 0001784567)
Harbor Custom Development, Inc. (CIK 0001784567)
Date: Dec. 19, 2023 · CIK: 0001784567 · Accession: 0000000000-23-013853
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File numbers found in text: 001-39266
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United States securities and exchange commission logo
December 19, 2023
Yoshi Niino
Chief Accounting Officer
Harbor Custom Development, Inc.
1201 Pacific Avenue, Suite 1200
Tacoma, WA 98402
Re:Harbor Custom Development, Inc.
Form 10-K for the Year Ended December 31, 2022
Filed March 31, 2023
File No. 001-39266
Dear Yoshi Niino:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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
the comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
FirstName LastNameYoshi Niino
Comapany NameHarbor Custom Development, Inc.
December 19, 2023 Page 2
FirstName LastName
Yoshi Niino
Harbor Custom Development, Inc.
December 19, 2023
Page 2
Form 10-K for the Year Ended December 31, 2022
Item 9A. Controls & Procedures, page 68
1.Please amend your filing to provide management's annual report on internal control over
financial reporting as of December 31, 2022; refer to Item 308(a) of Regulation S-K. In
addition, given the omission of your annual report on internal control over financial
reporting, tell us how you determined that your disclosure controls and procedures were
effective as of December 31, 2022.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact William Demarest at 202-551-3432 or Mark Rakip at 202-551-3573 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction