SEC Comment Letter 0000000000-25-010667 to SCE Recovery Funding LLC (CIK 0001826571)
SCE Recovery Funding LLC (CIK 0001826571)
Date: Sept. 30, 2025 · CIK: 0001826571 · Accession: 0000000000-25-010667
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-290112
Letter
Re: Southern California Edison Company SCE Recovery Funding LLC Registration Statement on Form SF-1 Filed September 8, 2025 File Nos. 333-290112 and 333-290112-01 Dear Steven D. Powell and Aaron D. Moss:
September 30, 2025
Steven D. Powell President and Chief Executive Officer Southern California Edison Company 2244 Walnut Grove Avenue P.O. Box 800 Rosemead, California 91770
Aaron D. Moss President and Manager SCE Recovery Funding LLC 2244 Walnut Grove Avenue P.O. Box 5407 Rosemead, California 91770
We have reviewed your registration statement 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. September 30, 2025 Page 2 Registration Statement on Form SF-1 Form of Prospectus Legal Proceedings, page 127
1. We note your statement that there are no legal or governmental proceedings pending against the sponsor, depositor, seller, or servicer, or of which any property of the foregoing is subject, that are material to the holders of the bonds. We also note, however, that the United States filed two lawsuits on or about September 4, 2025, seeking damages against Southern California Edison (SCE) in connection with the Eaton Fire of 2025 and the Fairview Fire of 2022. Please tell us why these legal proceedings, which may relate to SCE s role as sponsor, depositor and/or servicer are not material. Alternatively, revise your disclosure as necessary to describe any legal proceedings that are material to the purchasers of the bonds offered by this prospectus. Part II - Information Not Required in Prospectus Item 14. Exhibits, page 144
2. Please file the remaining exhibits with your next amendment. Refer to Item 1100(f) of Regulation AB and Instruction 1 to Item 601 of Regulation S-K. Note that we may have additional comments on your registration statement following our review of any such exhibits. 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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
Please contact Jason Weidberg at 202-551-6892 or Arthur Sandel at 202-551-3262 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Structured Finance
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> September 30, 2025 Steven D. Powell President and Chief Executive Officer Southern California Edison Company 2244 Walnut Grove Avenue P.O. Box 800 Rosemead, California 91770 Aaron D. Moss President and Manager SCE Recovery Funding LLC 2244 Walnut Grove Avenue P.O. Box 5407 Rosemead, California 91770 Re: Southern California Edison Company SCE Recovery Funding LLC Registration Statement on Form SF-1 Filed September 8, 2025 File Nos. 333-290112 and 333-290112-01 Dear Steven D. Powell and Aaron D. Moss: We have reviewed your registration statement 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. September 30, 2025 Page 2 Registration Statement on Form SF-1 Form of Prospectus Legal Proceedings, page 127 1. We note your statement that there are no legal or governmental proceedings pending against the sponsor, depositor, seller, or servicer, or of which any property of the foregoing is subject, that are material to the holders of the bonds. We also note, however, that the United States filed two lawsuits on or about September 4, 2025, seeking damages against Southern California Edison (SCE) in connection with the Eaton Fire of 2025 and the Fairview Fire of 2022. Please tell us why these legal proceedings, which may relate to SCE s role as sponsor, depositor and/or servicer are not material. Alternatively, revise your disclosure as necessary to describe any legal proceedings that are material to the purchasers of the bonds offered by this prospectus. Part II - Information Not Required in Prospectus Item 14. Exhibits, page 144 2. Please file the remaining exhibits with your next amendment. Refer to Item 1100(f) of Regulation AB and Instruction 1 to Item 601 of Regulation S-K. Note that we may have additional comments on your registration statement following our review of any such exhibits. 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Jason Weidberg at 202-551-6892 or Arthur Sandel at 202-551-3262 with any questions. Sincerely, Division of Corporation Finance Office of Structured Finance </TEXT> </DOCUMENT>