SEC Comment Letter for Capital Access Point III, Inc. (CIK 0001799815) — Mar 6, 2020
Capital Access Point III, Inc. (CIK 0001799815)
Date: March 6, 2020 · CIK: 0001799815 · Accession: 0000000000-20-002057
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File numbers found in text: 000-56138
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March 5, 2020
Jonathan Cross
President
Capital Access Point III, Inc.
c/o Shefford Advisors, LLC
477 Madison Avenue, Sixth Floor
New York, New York 10022
Re:Capital Access Point III, Inc.
Amendment No. 1 to Registration Statement on Form 10-12G
Filed February 25, 2020
File No. 000-56138
Dear Mr. Cross:
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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February 10, 2020 letter.
Form 10-12G/A filed February 25, 2020
Financial Statements, page F-1
1.Please amend your Form 10-12G to include audited financial statements for the year
ended December 31, 2019. Reference is made to Rule 8-08(b) of Regulation S-X.
Exhibits
2.We note your response to comment 8. Please file the company's bylaws as an exhibit or
advise. See Item 601 of Regulation S-K.
FirstName LastNameJonathan Cross
Comapany NameCapital Access Point III, Inc.
March 5, 2020 Page 2
FirstName LastName
Jonathan Cross
Capital Access Point III, Inc.
March 5, 2020
Page 2
You may contact Jorge Bonilla at 202-551-3414 or Wilson Lee at 202-551-3468 if you
have questions regarding comments on the financial statements and related matters. Please
contact Ronald (Ron) Alper at 202-551-3329 or Pam Long at 202-551-3765 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction