SEC Company Response from GenFlat Holdings, (GFLT) — Sep 22, 2020
GenFlat Holdings, Inc.
Date: Sept. 22, 2020 · CIK: 0001796949 · Accession: 0001654954-20-010340
AI Filing Summary & Sentiment
File numbers found in text: 333-239000
Referenced dates: September 18, 2020
Letter
hbr_corresp
Healthcare Business Resources, Inc.
718 Thompson Lane, Suite 108-273
Nashville, Tennessee 37204
September 22, 2020
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Ms. Cara Wirth
Ms. Mara Ransom
Re: Healthcare Business Resources, Inc.
Form S-1/A
Filed September 8, 2020
File No. 333-239000
Ladies and Gentlemen:
At the request of the U.S. Securities and Exchange Commission (the “Commission”), Healthcare Business Resources, Inc. (the “Company”) is providing this letter in response to the comments made in the Commission’s letter dated September 18, 2020. Your comments and the Company’s responses are set forth below.
Comment No.
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.
Response:
We modified the text on page 39. The value of the option grant exceeded the threshold amount in Item 404(d)(1)
Sincerely,
/s/ Stephen Epstein
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Healthcare Business Resources, Inc.
718 Thompson Lane, Suite 108-273
Nashville, Tennessee 37204
September
22, 2020
Division
of Corporation Finance
Securities
and Exchange Commission
100 F
Street, N.E.
Washington,
D.C. 20549
Attention:
Ms. Cara
Wirth
Ms. Mara
Ransom
Re:
Healthcare Business Resources, Inc.
Form S-1/A
Filed September 8, 2020
File No. 333-239000
Ladies
and Gentlemen:
At the request of the U.S. Securities and Exchange
Commission (the “Commission”), Healthcare Business Resources,
Inc. (the “Company”) is providing this letter in response to
the comments made in the Commission’s letter dated September
18, 2020. Your comments and the Company’s responses are set
forth below.
Comment No.
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.
Response:
We modified the
text on page 39. The value of the option grant exceeded the
threshold amount in Item 404(d)(1)
Sincerely,
/s/ Stephen Epstein
Stephen
Epstein
Chief
Executive Officer