SEC Comment Letter for Red Oak Capital Fund IV, LLC (CIK 0001794418) — Jan 14, 2020
Red Oak Capital Fund IV, LLC (CIK 0001794418)
Date: Jan. 14, 2020 · CIK: 0001794418 · Accession: 0000000000-20-000317
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File numbers found in text: 024-11118
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January 13, 2020
Chip Cummings
Chief Executive Officer of the Sole Member of the Manager
Red Oak Capital Fund IV, LLC
625 Kenmoor Avenue SE, Suite 211
Grand Rapids, MI 49546
Re:Red Oak Capital Fund IV, LLC
Amendment No. 1 to
Offering Statement on Form 1-A
Filed December 27, 2019
File No. 024-11118
Dear Mr. Cummings:
We have reviewed your amended offering statement and have the following comment. In
our comment, 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 comment applies 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 this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our December 16, 2019 letter.
Amendment No. 1 to Offering Statement on Form 1-A filed December 27, 2019
General
1.We note your response to comment 5 and that ROCF II and ROCF III have only just
commenced operations. However, based on the Form 1-SA filed on September 26, 2019
by ROCF II, it appears that ROCF II provided $20,041,750 of senior secured loans to
various borrowers. It appears that the sponsor's public track record of its prior programs
would present meaningful material information to investors. Please disclose the sponsor's
public track record, including acquisition data and commissions, management
compensation and other compensation data or provide us with a detailed analysis as to
why this information is not material to investors.
FirstName LastNameChip Cummings
Comapany NameRed Oak Capital Fund IV, LLC
January 13, 2020 Page 2
FirstName LastName
Chip Cummings
Red Oak Capital Fund IV, LLC
January 13, 2020
Page 2
You may contact Babette Cooper at 202-551-3396 or Eric McPhee at 202-551-3693 if
you have questions regarding comments on the financial statements and related matters. Please
contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction