SEC Comment Letter for Compound Projects, LLC (CIK 0001790166) — Jan 30, 2020
Compound Projects, LLC (CIK 0001790166)
Date: Jan. 30, 2020 · CIK: 0001790166 · Accession: 0000000000-20-000835
AI Filing Summary & Sentiment
File numbers found in text: 024-11133
Letter
January 29, 2020 Janine Yorio Chief Executive Officer Compound Projects, LLC 20 Clinton Street New York, NY 10002 Re:Compound Projects, LLC Amendment No. 1 to Form 1-A Filed January 10, 2020 File No. 024-11133 Dear Ms. Yorio: 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 January 6, 2020 letter. Form 1-A/A filed January 10, 2020 Interests of Management and Others in Certain Transactions, page 39 1.We note your revised disclosure and response to comment 2. Please confirm that any loan amounts converted into membership interests will count toward the maximum offering amount in Rule 251(a)(2). Consolidated Financial Statements and Independent Auditor’s Report Note 6. Subsequent Events, page F-5 2.We have considered your response to our prior comment 7 that the Series #Reach Property was vacant when Compound entered into the purchase and sale agreement for the property in October, 2019. Please clarify for us whether the property has been operated as
FirstName LastNameJanine Yorio Comapany NameCompound Projects, LLC January 29, 2020 Page 2 FirstName LastName Janine Yorio Compound Projects, LLC January 29, 2020 Page 2 a rental property at any time during the period from its development in 2016 through the date when Compound entered into the purchase and sale agreement for the property. 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 Stacie Gorman at 202-551-3585 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Paul C. Levites, Esq.
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January 29, 2020
Janine Yorio
Chief Executive Officer
Compound Projects, LLC
20 Clinton Street
New York, NY 10002
Re:Compound Projects, LLC
Amendment No. 1 to Form 1-A
Filed January 10, 2020
File No. 024-11133
Dear Ms. Yorio:
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 January 6, 2020 letter.
Form 1-A/A filed January 10, 2020
Interests of Management and Others in Certain Transactions, page 39
1.We note your revised disclosure and response to comment 2. Please confirm that any loan
amounts converted into membership interests will count toward the maximum offering
amount in Rule 251(a)(2).
Consolidated Financial Statements and Independent Auditor’s Report
Note 6. Subsequent Events, page F-5
2.We have considered your response to our prior comment 7 that the Series #Reach
Property was vacant when Compound entered into the purchase and sale agreement for the
property in October, 2019. Please clarify for us whether the property has been operated as
FirstName LastNameJanine Yorio
Comapany NameCompound Projects, LLC
January 29, 2020 Page 2
FirstName LastName
Janine Yorio
Compound Projects, LLC
January 29, 2020
Page 2
a rental property at any time during the period from its development in 2016 through the
date when Compound entered into the purchase and sale agreement for the property.
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 Stacie Gorman at 202-551-3585 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Paul C. Levites, Esq.