SEC Comment Letter 0000000000-24-001098 to RSE Innovation, LLC (CIK 0001812859)
RSE Innovation, LLC (CIK 0001812859)
Date: Jan. 29, 2024 · CIK: 0001812859 · Accession: 0000000000-24-001098
AI Filing Summary & Sentiment
File numbers found in text: 024-11612
Letter
United States securities and exchange commission logo January 29, 2024 Christopher J. Bruno Chief Executive Officer & President RSE Innovation, LLC 446 Broadway, 2nd Floor New York, NY 10013 Re:RSE Innovation, LLC Offering Statement on Form 1-A Post-Qualification Amendment No. 9 Filed January 4, 2024 File No. 024-11612 Dear Christopher J. Bruno: We have reviewed your amendment and have the following comment. Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Post-Qualification Amendment No. 9 Filed January 4, 2024 Management Asset Manager Responsibilities of the Asset Manager, page 77 1.We note your statements that the Asset Manager is responsible for "[e]ngag[ing] third- party independent contractors for the care, custody, maintenance and management of the Underlying Assets" and "perform[ing] any other act necessary to carry out all asset management ... obligations." Please provide specific examples of such duties and obligations to be carried out by DomianX in its role as Asset Manager of Series #URL5 and #URL6. 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.
FirstName LastNameChristopher J. Bruno Comapany NameRSE Innovation, LLC January 29, 2024 Page 2 FirstName LastName Christopher J. Bruno RSE Innovation, LLC January 29, 2024 Page 2 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 Cara Wirth at 202-551-7127 or Donald Field at 202-551-3680 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Lori Metrock
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United States securities and exchange commission logo
January 29, 2024
Christopher J. Bruno
Chief Executive Officer & President
RSE Innovation, LLC
446 Broadway, 2nd Floor
New York, NY 10013
Re:RSE Innovation, LLC
Offering Statement on Form 1-A
Post-Qualification Amendment No. 9
Filed January 4, 2024
File No. 024-11612
Dear Christopher J. Bruno:
We have reviewed your amendment and have the following comment.
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Post-Qualification Amendment No. 9 Filed January 4, 2024
Management
Asset Manager
Responsibilities of the Asset Manager, page 77
1.We note your statements that the Asset Manager is responsible for "[e]ngag[ing] third-
party independent contractors for the care, custody, maintenance and management of the
Underlying Assets" and "perform[ing] any other act necessary to carry out all asset
management ... obligations." Please provide specific examples of such duties and
obligations to be carried out by DomianX in its role as Asset Manager of Series #URL5
and #URL6.
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.
FirstName LastNameChristopher J. Bruno
Comapany NameRSE Innovation, LLC
January 29, 2024 Page 2
FirstName LastName
Christopher J. Bruno
RSE Innovation, LLC
January 29, 2024
Page 2
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 Cara Wirth at 202-551-7127 or Donald Field at 202-551-3680 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Lori Metrock