SEC Comment Letter for GenFlat Holdings, (GFLT) — Sep 18, 2020
GenFlat Holdings, Inc.
Date: Sept. 18, 2020 · CIK: 0001796949 · Accession: 0000000000-20-008841
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-239000
Letter
United States securities and exchange commission logo September 18, 2020 Stephen Epstein Chief Executive Officer Healthcare Business Resources, Inc. 718 Thompson Lane, Suite 108-273 Nashville, Tennessee 37204 Re:Healthcare Business Resources, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed September 9, 2020 File No. 333-239000 Dear Mr. Epstein: We have reviewed your amended registration 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 registration 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 registration statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 2 to Registration Statement on Form S-1 filed September 9, 2020 Transactions with Related Persons, page 30 1.Please update the "Promoters and control persons" disclosure to account for the August 8, 2020 grant of non-qualified stock options to Joel Arberman. Refer to Item 404(c)(1)(i) of Regulation S-K. Additionally, please tell us what consideration you gave to disclosing this option grant in accordance with Item 404(a) of Regulation S-K and, if applicable, please include the required disclosure in this section.
FirstName LastNameStephen Epstein Comapany NameHealthcare Business Resources, Inc. September 18, 2020 Page 2 FirstName LastName Stephen Epstein Healthcare Business Resources, Inc. September 18, 2020 Page 2 You may contact Aamira Chaudhry at (202) 551-3389 or Lyn Shenk at (202) 551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202) 551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Joel Arberman
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United States securities and exchange commission logo
September 18, 2020
Stephen Epstein
Chief Executive Officer
Healthcare Business Resources, Inc.
718 Thompson Lane, Suite 108-273
Nashville, Tennessee 37204
Re:Healthcare Business Resources, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed September 9, 2020
File No. 333-239000
Dear Mr. Epstein:
We have reviewed your amended registration 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 registration 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 registration statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 2 to Registration Statement on Form S-1 filed September 9, 2020
Transactions with Related Persons, page 30
1.Please update the "Promoters and control persons" disclosure to account for the August 8,
2020 grant of non-qualified stock options to Joel Arberman. Refer to Item 404(c)(1)(i) of
Regulation S-K. Additionally, please tell us what consideration you gave to disclosing this
option grant in accordance with Item 404(a) of Regulation S-K and, if applicable, please
include the required disclosure in this section.
FirstName LastNameStephen Epstein
Comapany NameHealthcare Business Resources, Inc.
September 18, 2020 Page 2
FirstName LastName
Stephen Epstein
Healthcare Business Resources, Inc.
September 18, 2020
Page 2
You may contact Aamira Chaudhry at (202) 551-3389 or Lyn Shenk at (202) 551-3380 if
you have questions regarding comments on the financial statements and related matters. Please
contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202) 551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Joel Arberman