SEC Company Response from Compound Projects, LLC (CIK 0001790166) — Nov 17, 2020
Compound Projects, LLC (CIK 0001790166)
Date: Nov. 17, 2020 · CIK: 0001790166 · Accession: 0001387131-20-010060
AI Filing Summary & Sentiment
File numbers found in text: 024-11133
Referenced dates: November 9, 2020
Letter
Compound Projects, LLC
335 Madison Ave. 16th Floor
New York, NY 10017
November 17, 2020
VIA EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Division of Corporate Finance
Office of Real Estate & Construction
Attn. Ruairi Regan
Re: Compound Projects, LLC
Post Qualification Amendment on Form 1-A
Filed October 22, 2020
File No. 024-11133
Mr. Regan,
We hereby submit the responses of Compound Projects, LLC (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter to us, dated November 9, 2020, providing the Staff’s comments with respect to the Post Qualification Amendment on Form 1-A, publicly filed with the Commission on October 22, 2020. Concurrently with the filing of this response letter, we have publicly filed a further amendment to the Post Qualification Amendment on Form 1-A (the “Form 1-A/POS AM”), and the publicly filed Form 1-A/POS AM incorporates our changes as indicated below made in response to the Staff’s comments.
For the convenience of the Staff, we have listed below, in summary fashion, the Staff’s comment followed by the response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.
DESCRIPTION OF SERIES #REACH, page 38
1. We note your disclosure that you entered into an agreement on April 6, 2020 to lease the 1805 Reach Brickell property. Please file the lease agreement as an exhibit or advise.
Response: We have revised the disclosure on page 38 of the offering circular contained within the Form 1-A/POS AM to reflect that the aforementioned lease was terminated on November 4, 2020. We have also included disclosure relating to the terms of the lease termination and our plans for the property moving forward. As such, we believe that the lease is no longer material.
If you would like to discuss our response to the Staff’s comment or if you would like to discuss any other matters, please contact Jesse Stein, Chief Operating Officer of the Company at (347) 585-8798 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).
Sincerely,
Compound Projects, LLC
Show Raw Text
CORRESP
1
filename1.htm
Compound Projects, LLC
335 Madison Ave. 16th Floor
New York, NY 10017
November 17, 2020
VIA EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Division of Corporate Finance
Office of Real Estate & Construction
Attn. Ruairi Regan
Re:
Compound Projects, LLC
Post Qualification Amendment on Form 1-A
Filed October 22, 2020
File No. 024-11133
Mr. Regan,
We hereby submit the responses of Compound Projects,
LLC (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”) set forth in the Staff’s letter to us, dated November 9, 2020, providing the Staff’s
comments with respect to the Post Qualification Amendment on Form 1-A, publicly filed with the Commission on October 22, 2020.
Concurrently with the filing of this response letter, we have publicly filed a further amendment to the Post Qualification Amendment
on Form 1-A (the “Form 1-A/POS AM”), and the publicly filed Form 1-A/POS AM incorporates our changes as indicated below
made in response to the Staff’s comments.
For the convenience of the Staff, we have listed
below, in summary fashion, the Staff’s comment followed by the response of the Company. Unless the context indicates
otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated
basis.
DESCRIPTION OF SERIES #REACH, page 38
1. We note your disclosure that you entered into an agreement on
April 6, 2020 to lease the 1805 Reach Brickell property. Please file the lease agreement as an exhibit or advise.
Response: We have revised the disclosure on page 38 of the
offering circular contained within the Form 1-A/POS AM to reflect that the aforementioned lease was terminated on November 4, 2020.
We have also included disclosure relating to the terms of the lease termination and our plans for the property moving forward.
As such, we believe that the lease is no longer material.
If you would like to discuss our response to
the Staff’s comment or if you would like to discuss any other matters, please contact Jesse Stein, Chief Operating Officer
of the Company at (347) 585-8798 or Louis A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).
Sincerely,
Compound Projects, LLC
By: Compound Asset Management, LLC, its managing member
By:
/s/ Jesse Stein
Jesse Stein
Chief Operating Officer