SEC Comment Letter for Otis Collection LLC (CIK 0001795168) — Nov 16, 2021
Otis Collection LLC (CIK 0001795168)
Date: Nov. 16, 2021 · CIK: 0001795168 · Accession: 0000000000-21-013849
AI Filing Summary & Sentiment
File numbers found in text: 024-11521
Letter
United States securities and exchange commission logo November 16, 2021 Michael Karnjanaprakorn Chief Executive Officer Otis Collection LLC 335 Madison Ave, 16th Floor New York, NY 10017 Re:Otis Collection LLC Post-Qualification Amendment No. 5 to Form 1-A Response dated October 28, 2021 File No. 024-11521 Dear Mr. Karnjanaprakorn: We have reviewed your amendment 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. Post-Qualification Amendment No. 5 to Form 1-A Description of Business Liquidity Platform, page 85 1.Please revise your disclosure to describe (1) whether investors holding your securities can freely trade the securities on any trading venue other than the PPEX ATS, (2) whether your investors are limited to using the Liquidity Platform tool to enter orders into the PPEX ATS or into any other trading venue, such as another ATS, and (3) whether your investors are required to use the introducing broker that is referred to in the disclosures to trade the securities in any way. We will consider qualifying your offering statement at your request. If a participant in your offering is required to clear its compensation arrangements with FINRA, please have FINRA advise us that it has no objections to the compensation arrangements prior to qualification.
FirstName LastNameMichael Karnjanaprakorn Comapany NameOtis Collection LLC November 16, 2021 Page 2 FirstName LastName Michael Karnjanaprakorn Otis Collection LLC November 16, 2021 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jacqueline Kaufman at 202-551-3797 or Erin Jaskot at 202-551-3442 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
November 16, 2021
Michael Karnjanaprakorn
Chief Executive Officer
Otis Collection LLC
335 Madison Ave, 16th Floor
New York, NY 10017
Re:Otis Collection LLC
Post-Qualification Amendment No. 5 to Form 1-A
Response dated October 28, 2021
File No. 024-11521
Dear Mr. Karnjanaprakorn:
We have reviewed your amendment 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.
Post-Qualification Amendment No. 5 to Form 1-A
Description of Business
Liquidity Platform, page 85
1.Please revise your disclosure to describe (1) whether investors holding your securities can
freely trade the securities on any trading venue other than the PPEX ATS, (2) whether
your investors are limited to using the Liquidity Platform tool to enter orders into the
PPEX ATS or into any other trading venue, such as another ATS, and (3) whether your
investors are required to use the introducing broker that is referred to in the disclosures to
trade the securities in any way.
We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
FirstName LastNameMichael Karnjanaprakorn
Comapany NameOtis Collection LLC
November 16, 2021 Page 2
FirstName LastName
Michael Karnjanaprakorn
Otis Collection LLC
November 16, 2021
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact Jacqueline Kaufman at 202-551-3797 or Erin Jaskot at 202-551-3442 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services