SEC Comment Letter 0000000000-24-012361 to Abacus Global Management, Inc. (ABX)
Abacus Global Management, Inc.
Date: Nov. 6, 2024 · CIK: 0001814287 · Accession: 0000000000-24-012361
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-282747
Letter
November 6, 2024 Jay J. Jackson President and CEO Abacus Life, Inc. 2101 Park Center Drive, Suite 200 Orlando, FL 32835 Re:Abacus Life, Inc. Registration Statement on Form S-3 Filed October 21, 2024 Response Letter Submitted November 4, 2024 File No. 333-282747 Dear Jay J. Jackson: We have reviewed your response letter received November 4, 2024 and have the following comments. Please respond to this letter by amending your registration 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 registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our November 1, 2024 letter. Response Letter Received November 4, 2024 Risk Factors , page 6 1.We note your response to comment one and two, noting Mr. Jackson's vacated director role and your ownership interest in Lapetus. We also note that Lapetus provides information that is incorporated into your underwriting model. Revise your risk factor disclosure related to the potential to misvalue life insurance policies to note your ownership interest in one of the service providers that support your valuation activities. Please contact Madeleine Mateo at 202-551-3465 or Christian Windsor at 202-551- 3419 with any questions.
November 6, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Finance cc:Ryan Maierson, Esq.
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November 6, 2024
Jay J. Jackson
President and CEO
Abacus Life, Inc.
2101 Park Center Drive, Suite 200
Orlando, FL 32835
Re:Abacus Life, Inc.
Registration Statement on Form S-3 Filed October 21, 2024
Response Letter Submitted November 4, 2024
File No. 333-282747
Dear Jay J. Jackson:
We have reviewed your response letter received November 4, 2024 and have the
following comments.
Please respond to this letter by amending your registration 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 registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our November 1, 2024 letter.
Response Letter Received November 4, 2024
Risk Factors , page 6
1.We note your response to comment one and two, noting Mr. Jackson's vacated
director role and your ownership interest in Lapetus. We also note that Lapetus
provides information that is incorporated into your underwriting model. Revise your
risk factor disclosure related to the potential to misvalue life insurance policies to note
your ownership interest in one of the service providers that support your valuation
activities.
Please contact Madeleine Mateo at 202-551-3465 or Christian Windsor at 202-551-
3419 with any questions.
November 6, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Ryan Maierson, Esq.