SEC Comment Letter for Compound Projects, LLC (CIK 0001790166) — Feb 18, 2020
Compound Projects, LLC (CIK 0001790166)
Date: Feb. 18, 2020 · CIK: 0001790166 · Accession: 0000000000-20-001465
AI Filing Summary & Sentiment
File numbers found in text: 024-11133
Letter
February 14, 2020 Janine Yorio Chief Executive Officer Compound Projects, LLC 20 Clinton Street New York, NY 10002 Re:Compound Projects, LLC Amendment No. 2 to Form 1-A Filed January 31, 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 29, 2020 letter. Form 1-A/A filed January 31, 2020 Consolidated Financial Statements and Independent Auditor’s Report Note 6. Subsequent Events, page F-5 1.We have considered your response to our prior comment 2. Please provide us with more detail related to the prior rental history of the property. In your response, tell us the approximate commencement dates and occupancy periods for each lease. Also, please tell us whether you have identified a potential tenant to occupy the property. General 2.We note the link on your website to your mobile app. Testimonials on the site suggest your offering has commenced. Please advise us if the offering has commenced. We also
FirstName LastNameJanine Yorio Comapany NameCompound Projects, LLC February 14, 2020 Page 2 FirstName LastName Janine Yorio Compound Projects, LLC February 14, 2020 Page 2 note a testimonial that your app is a "[g]reat way to diversify ... and so easy to buy and sell shares of real estate in hot markets." Please advise us of the functions and capabilities of your platform. For example, are purchasers able to sell their membership interests? 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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February 14, 2020
Janine Yorio
Chief Executive Officer
Compound Projects, LLC
20 Clinton Street
New York, NY 10002
Re:Compound Projects, LLC
Amendment No. 2 to Form 1-A
Filed January 31, 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 29, 2020 letter.
Form 1-A/A filed January 31, 2020
Consolidated Financial Statements and Independent Auditor’s Report
Note 6. Subsequent Events, page F-5
1.We have considered your response to our prior comment 2. Please provide us with more
detail related to the prior rental history of the property. In your response, tell us the
approximate commencement dates and occupancy periods for each lease. Also, please
tell us whether you have identified a potential tenant to occupy the property.
General
2.We note the link on your website to your mobile app. Testimonials on the site suggest
your offering has commenced. Please advise us if the offering has commenced. We also
FirstName LastNameJanine Yorio
Comapany NameCompound Projects, LLC
February 14, 2020 Page 2
FirstName LastName
Janine Yorio
Compound Projects, LLC
February 14, 2020
Page 2
note a testimonial that your app is a "[g]reat way to diversify ... and so easy to buy and sell
shares of real estate in hot markets." Please advise us of the functions and capabilities of
your platform. For example, are purchasers able to sell their membership interests?
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.