SEC Comment Letter 0000000000-24-012368 to Abacus Global Management, Inc. (ABX)
Abacus Global Management, Inc.
Date: Nov. 7, 2024 · CIK: 0001814287 · Accession: 0000000000-24-012368
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-273411
Referenced dates: November 4, 2024
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. Post-Effective Amendment No. 1 to Registration Statement on Form S-1 on Form S-3 Filed October 21, 2024 Response Letter Dated November 4, 2024 File Number 333-273411 Dear Jay J. Jackson: We have reviewed your response letter dated 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. Response Letter Received November 4, 2024 Risk Factors, page 8 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. 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
November 6, 2024 Page 2 of action by the staff. Please contact Christian Windsor at 202-551-3419 with any questions. 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.
Post-Effective Amendment No. 1 to Registration Statement on Form S-1 on
Form S-3
Filed October 21, 2024
Response Letter Dated November 4, 2024
File Number 333-273411
Dear Jay J. Jackson:
We have reviewed your response letter dated 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.
Response Letter Received November 4, 2024
Risk Factors, page 8
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.
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
November 6, 2024
Page 2
of action by the staff.
Please contact Christian Windsor at 202-551-3419 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Ryan Maierson, Esq.