SEC Comment Letter for Aspire Real Estate Investors, Inc. (CIK 0001800491) — Nov 12, 2020
Aspire Real Estate Investors, Inc. (CIK 0001800491)
Date: Nov. 12, 2020 · CIK: 0001800491 · Accession: 0000000000-20-010834
AI Filing Summary & Sentiment
File numbers found in text: 333-249285
Letter
United States securities and exchange commission logo November 12, 2020 Daryl J. Carter President and Chief Executive Officer Aspire Real Estate Investors, Inc. 1920 Main Street, Suite 150 Irvine, CA 92614 Re:Aspire Real Estate Investors, Inc. Amendment No. 2 to Registration Statement on Form S-11 Filed November 6, 2020 File No. 333-249285 Dear Mr. Carter: We have reviewed your amended registration statement 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 registration 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 registration statement and the information you provide in response to these comments, we may have additional comments. Amendment No. 2 to Form S-11 filed November 6, 2020 Unaudited Pro Forma Condensed Combined Balance Sheet, page F-4 1.We note that total assets on a pro forma basis does not foot correctly. Please revise accordingly. Unaudited Pro Forma Condensed Combined Statements of Operations, page F-7 2.We note that net income (loss) attributable to noncontrolling interests for the nine months ended September 30, 2020 and for the year ended December 31, 2019 reflect net income amounts. Please revise these amounts to reflect net (loss) for the respective periods and ensure it is revised consistently throughout the filing. You may contact Isaac Esquivel at (202) 551-3395 or Kristi Marrone at (202) 551-3429 if
FirstName LastNameDaryl J. Carter Comapany NameAspire Real Estate Investors, Inc. November 12, 2020 Page 2 FirstName LastName Daryl J. Carter Aspire Real Estate Investors, Inc. November 12, 2020 Page 2 you have questions regarding comments on the financial statements and related matters. Please contact Ruairi Regan at (202) 551-3269 or James Lopez at (202) 551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Daniel M. LeBey, Esq.
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United States securities and exchange commission logo
November 12, 2020
Daryl J. Carter
President and Chief Executive Officer
Aspire Real Estate Investors, Inc.
1920 Main Street, Suite 150
Irvine, CA 92614
Re:Aspire Real Estate Investors, Inc.
Amendment No. 2 to Registration Statement on Form S-11
Filed November 6, 2020
File No. 333-249285
Dear Mr. Carter:
We have reviewed your amended registration statement 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 registration 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 2 to Form S-11 filed November 6, 2020
Unaudited Pro Forma Condensed Combined Balance Sheet, page F-4
1.We note that total assets on a pro forma basis does not foot correctly. Please revise
accordingly.
Unaudited Pro Forma Condensed Combined Statements of Operations, page F-7
2.We note that net income (loss) attributable to noncontrolling interests for the nine months
ended September 30, 2020 and for the year ended December 31, 2019 reflect net income
amounts. Please revise these amounts to reflect net (loss) for the respective periods and
ensure it is revised consistently throughout the filing.
You may contact Isaac Esquivel at (202) 551-3395 or Kristi Marrone at (202) 551-3429 if
FirstName LastNameDaryl J. Carter
Comapany NameAspire Real Estate Investors, Inc.
November 12, 2020 Page 2
FirstName LastName
Daryl J. Carter
Aspire Real Estate Investors, Inc.
November 12, 2020
Page 2
you have questions regarding comments on the financial statements and related matters. Please
contact Ruairi Regan at (202) 551-3269 or James Lopez at (202) 551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Daniel M. LeBey, Esq.