Correspondence 0001628280-24-028475 from Abacus Global Management, Inc. (ABX)
Abacus Global Management, Inc.
Date: June 17, 2024 · CIK: 0001814287 · Accession: 0001628280-24-028475
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File numbers found in text: 333-279347
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CORRESP 1 filename1.htm Document VIA EDGAR Piper Sandler & Co. 1251 Avenue of the Americas, 6th Floor New York, New York 10020 TD Securities (USA) LLC 1 Vanderbilt Avenue New York, New York 10017 B. Riley Securities, Inc. 1300 17th Street North, Suite 1300 Arlington, Virginia 22209 KKR Capital Markets LLC 30 Hudson Yards, 75th Floor New York, New York 10001 June 17, 2024 Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Aisha Adegbuyi Christian Windsor Re: Abacus Life, Inc. Registration Statement on Form S-1 File No. 333-279347 Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Abacus Life, Inc. (the “Company”) for acceleration of the effective date of the above-named Registration Statement on Form S-1, as amended, so that it becomes effective at 2:00 PM, Eastern Time, on June 20, 2024 or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Latham & Watkins LLP, may orally request via telephone call that such Registration Statement be declared effective. Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that we intend to distribute to each underwriter, dealer or institution who is reasonably anticipated to participate in the offering as many copies of the Preliminary Prospectus included in the above-named Registration Statement, as amended, as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus. We, the undersigned, as representatives of the several underwriters, confirm on behalf of ourselves and the other participating underwriters that we have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issuance. [Signature Page Follows] Very truly yours, Acting on behalf of themselves and the several underwriters PIPER SANDLER & CO. By: /s/ Michael Basset Name: Michael Basset Title: Managing Director TD SECURITIES (USA) LLC By: /s/ Scott Robertson Name: Scott Robertson Title: Managing Director B. RILEY SECURITIES, INC. By: /s/ Jimmy Baker Name: Jimmy Baker Title: President KKR CAPITAL MARKETS LLC By: /s/ David Bauer Name: David Bauer Title: Managing Director Signature Page to Acceleration Request