SEC Comment Letter for Otis Collection LLC (CIK 0001795168) — Mar 10, 2020
Otis Collection LLC (CIK 0001795168)
Date: March 10, 2020 · CIK: 0001795168 · Accession: 0000000000-20-002150
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File numbers found in text: 024-11126
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March 10, 2020
Michael Karnjanaprakorn
Chief Executive Officer
Otis Collection LLC
335 Madison Ave, 3rd Floor
New York, NY 10017
Re:Otis Collection LLC
Amednment No. 2 to Offering Statement on Form 1-A
Filed February 12, 2020
File No. 024-11126
Dear Mr. Karnjanaprakorn:
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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our January 27, 2020 letter.
Offering Statement on Form 1-A
Liquidity Platform, page 45
1.We note your revisions to your description of the liquidity platform. Please confirm that
when your liquidity platform is operational, you will update your disclosure to identify the
broker-dealer you have retained and provide further clarity as to your intended use of an
ATS.
FirstName LastNameMichael Karnjanaprakorn
Comapany NameOtis Collection LLC
March 10, 2020 Page 2
FirstName LastName
Michael Karnjanaprakorn
Otis Collection LLC
March 10, 2020
Page 2
You may contact Scott Anderegg, Staff Attorney at 202-551-3342 or Mara Ransom,
Office Chief at 202-551-3264 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services