SEC Comment Letter for Collectable Sports Assets, LLC (CIK 0001804446) — Mar 4, 2022
Collectable Sports Assets, LLC (CIK 0001804446)
Date: March 4, 2022 · CIK: 0001804446 · Accession: 0000000000-22-002486
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File numbers found in text: 024-11178
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United States securities and exchange commission logo
March 4, 2022
Ezra Levine
Chief Executive Officer
Collectable Sports Assets, LLC
333 Westchester Avenue, Suite W2100
White Plains, NY 10604
Re:Collectable Sports Assets, LLC
Post-qualification Amendment No. 19 to Form 1-A
Filed February 11, 2022
File No. 024-11178
Dear Mr. Levine:
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. 19 to Form 1-A Filed February 11, 2022
Use of Proceeds and Descriptions of Underlying Assets, page 34
1.Your disclosure in this section indicates that a number of consignment agreements for
series currently being offered have expired (see, e.g., #MAYS1957LADDERBASKET
and #KAREEMPOINTSRECORDBALL). Please revise to indicate whether you have
entered into new or amended consignment agreements for extended periods as exhibits
and amend your disclosure to reflect the revised terms, or advise as to the status of these
series.
General
2.Please revise the offering table on the cover page to indicate the initial qualification date
and day in which offers commenced for each of the fifteen series that you are amending,
but not currently offering. In addition, please clarify for us what you mean by your
reference that these offerings are "to commence immediately following qualification." To
FirstName LastNameEzra Levine
Comapany NameCollectable Sports Assets, LLC
March 4, 2022 Page 2
FirstName LastName
Ezra Levine
Collectable Sports Assets, LLC
March 4, 2022
Page 2
the extent each of these offerings were not commenced within two calendar days after
they were initially qualified, please explain why you believe these offerings comply
with Rule 251(d)(3)(i)(F).
3.We note that you have lowered the total minimum offering amounts for the Series
#KOUFAXPSA8 and #GRIFFEY89UPPERDECKSGCGOLD offerings, but continue to
offer these Series. We also note that you intend to lower the total minimum offering
amount for most of the fifteen series you are amending, but not currently offering. Please
confirm whether any sales have been made under these offerings. To the extent you have
made sales under these offerings, explain how you will comply with Exchange Act Rule
10b-9.
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.
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 Nicholas Lamparski at 202-551-4695 or Mara Ransom at 202-551-3264
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Gary Brown