SEC Comment Letter 0000000000-23-005983 to Groundfloor Yield LLC (CIK 0001810007)
Groundfloor Yield LLC (CIK 0001810007)
Date: June 5, 2023 · CIK: 0001810007 · Accession: 0000000000-23-005983
AI Filing Summary & Sentiment
File numbers found in text: 024-11411
Letter
United States securities and exchange commission logo June 5, 2023 Nick Bhargava Chief Financial Officer Groundfloor Yield LLC 600 Peachtree Street, Suite 810 Atlanta, GA 30308 Re:Groundfloor Yield LLC Offering Statement on Form 1-A Post-qualification Amendment Filed May 19, 2023 File No. 024-11411 Dear Nick Bhargava:
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 to Form 1-A filed May 19, 2023 General 1.We note the risk factor added on page 15 in response to comment 1. Please remove the reference to an insignificant deviation under Rule 260(a) as the risk factors section should not contain mitigating language. In addition, please clearly disclose the amount of securities sold during the time period that may be subject to rescission claims. 2.We continue to consider you auto-invest and rollover programs.
FirstName LastNameNick Bhargava Comapany NameGroundfloor Yield LLC June 5, 2023 Page 2 FirstName LastName Nick Bhargava Groundfloor Yield LLC June 5, 2023 Page 2 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 Pearlyne Paulemon at 202-551-8714 or Pam Howell at 202-551-3357 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Brian Korn, Esq.
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United States securities and exchange commission logo
June 5, 2023
Nick Bhargava
Chief Financial Officer
Groundfloor Yield LLC
600 Peachtree Street, Suite 810
Atlanta, GA 30308
Re:Groundfloor Yield LLC
Offering Statement on Form 1-A
Post-qualification Amendment
Filed May 19, 2023
File No. 024-11411
Dear Nick Bhargava:
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 to Form 1-A filed May 19, 2023
General
1.We note the risk factor added on page 15 in response to comment 1. Please remove the
reference to an insignificant deviation under Rule 260(a) as the risk factors section should
not contain mitigating language. In addition, please clearly disclose the amount of
securities sold during the time period that may be subject to rescission claims.
2.We continue to consider you auto-invest and rollover programs.
FirstName LastNameNick Bhargava
Comapany NameGroundfloor Yield LLC
June 5, 2023 Page 2
FirstName LastName
Nick Bhargava
Groundfloor Yield LLC
June 5, 2023
Page 2
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 Pearlyne Paulemon at 202-551-8714 or Pam Howell at 202-551-3357 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Brian Korn, Esq.