SEC Comment Letter for Gladstone Companies, Inc. (CIK 0001805586) — Jun 11, 2020
Gladstone Companies, Inc. (CIK 0001805586)
Date: June 11, 2020 · CIK: 0001805586 · Accession: 0000000000-20-005202
AI Filing Summary & Sentiment
File numbers found in text: 024-11232
Letter
United States securities and exchange commission logo June 11, 2020 David Gladstone President and Chief Executive Officer The Gladstone Companies, Inc. 1521 Westbranch Drive, Suite 100 McLean, VA 22102 Re:The Gladstone Companies, Inc. Offering Statement on Form 1-A Filed June 2, 2020 File No. 024-11232 Dear Mr. Gladstone: We have reviewed your offering 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 providing the requested information or amending your offering statement. 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 the information you provide in response to these comments or any amendment to your offering statement, we may have additional comments. Offering Statement Submitted June 2, 2020 Offering Circular Summary Recent Developments, page 7 1.We note your response to comment 3 and your updates to performance percentages and other metrics through December 31, 2019. Please confirm to us that there have not been any material changes to these percentages and metrics since December 31, 2019. 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
FirstName LastNameDavid Gladstone Comapany NameThe Gladstone Companies, Inc. June 11, 2020 Page 2 FirstName LastName David Gladstone The Gladstone Companies, Inc. June 11, 2020 Page 2 action by the staff. We also remind you that, following qualification of your Form 1-A, Rule 257 of Regulation A requires you to file periodic and current reports, including a Form 1-K which will be due within 120 calendar days after the end of the fiscal year covered by the report. Please contact David Gessert at 202-551-2326 or Michael Clampitt at 202-551-3434 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: Erin M. Lett
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United States securities and exchange commission logo
June 11, 2020
David Gladstone
President and Chief Executive Officer
The Gladstone Companies, Inc.
1521 Westbranch Drive, Suite 100
McLean, VA 22102
Re:The Gladstone Companies, Inc.
Offering Statement on Form 1-A
Filed June 2, 2020
File No. 024-11232
Dear Mr. Gladstone:
We have reviewed your offering 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 providing the requested information or amending your
offering statement. 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 the information you provide in response to these comments or any amendment to your
offering statement, we may have additional comments.
Offering Statement Submitted June 2, 2020
Offering Circular Summary
Recent Developments, page 7
1.We note your response to comment 3 and your updates to performance percentages and
other metrics through December 31, 2019. Please confirm to us that there have not been
any material changes to these percentages and metrics since December 31, 2019.
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
FirstName LastNameDavid Gladstone
Comapany NameThe Gladstone Companies, Inc.
June 11, 2020 Page 2
FirstName LastName
David Gladstone
The Gladstone Companies, Inc.
June 11, 2020
Page 2
action by the staff. We also remind you that, following qualification of your Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.
Please contact David Gessert at 202-551-2326 or Michael Clampitt at 202-551-3434 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Erin M. Lett