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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

AI Filing Summary & Sentiment

File numbers found in text: 024-11118

Date
January 13, 2020
Author
Not clearly detected
Form
UPLOAD
Company
Red Oak Capital Fund IV, LLC (CIK 0001794418)

Letter

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

Show Raw Text
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