SEC Comment Letter 0000000000-24-007906 to Connect Invest II LLC (CIK 0001831623)
Connect Invest II LLC (CIK 0001831623)
Date: July 12, 2024 · CIK: 0001831623 · Accession: 0000000000-24-007906
AI Filing Summary & Sentiment
File numbers found in text: 024-12415
Letter
July 11, 2024 Todd B. Parriott Chief Executive Officer Connect Invest II LLC 6700 Via Austi Parkway, Suite E Las Vegas, Nevada 89119 Re:Connect Invest II LLC Amendment No. 1 to Offering Statement on Form 1-A Filed June 18, 2024 File No. 024-12415 Dear Todd B. Parriott: We have reviewed your amended offering statement 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. Amendment No. 1 to Offering Statement on Form 1-A filed June 18, 2024 Notes to Financial Statements Note 3 - Loan Receivable, net, page F-10 We note your enhancements to the Allowance for Credit Losses, Note 2, and Loans Receivable disclosure and the overall composition of your loans receivable between commercial and residential loan categories, and their maturities schedule in Note 3. Please tell us how you considered expected credit losses on a collective basis of loans with similar risk characteristics, to permit an investor to understand the following; refer to ASC 326-20-50: •Your portfolio-level detail to include internal risk ratings used, allocation among different loan-to-value or loan-to-cost ratios, organization or maturity dates, or any other relevant factors used in assessing the quality of loans receivable; and Whether you have a significant asset concentration of loans receivable outstanding, detailing the number of loans within each of your self-identified pooled loan characteristics, and if any such loans are significant at the 20% level on an individual •1.
July 11, 2024 Page 2 basis. To the extent any loan receivable on an individual basis exceeds 20%, tell us how you considered Staff Accounting Bulletin Topic 1.I. regarding financial statements of properties underlying loans. Please contact Kellie Kim at 202-551-3129 or Mark Rakip at 202-551-3573 if you have questions regarding comments on the financial statements and related matters. Please contact Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Ken Betts
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July 11, 2024
Todd B. Parriott
Chief Executive Officer
Connect Invest II LLC
6700 Via Austi Parkway, Suite E
Las Vegas, Nevada 89119
Re:Connect Invest II LLC
Amendment No. 1 to Offering Statement on Form 1-A
Filed June 18, 2024
File No. 024-12415
Dear Todd B. Parriott:
We have reviewed your amended offering statement 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.
Amendment No. 1 to Offering Statement on Form 1-A filed June 18, 2024
Notes to Financial Statements
Note 3 - Loan Receivable, net, page F-10
We note your enhancements to the Allowance for Credit Losses, Note 2, and Loans
Receivable disclosure and the overall composition of your loans receivable between
commercial and residential loan categories, and their maturities schedule in Note
3. Please tell us how you considered expected credit losses on a collective basis of loans
with similar risk characteristics, to permit an investor to understand the following; refer to
ASC 326-20-50:
•Your portfolio-level detail to include internal risk ratings used, allocation among
different loan-to-value or loan-to-cost ratios, organization or maturity dates, or any
other relevant factors used in assessing the quality of loans receivable; and
Whether you have a significant asset concentration of loans receivable outstanding,
detailing the number of loans within each of your self-identified pooled loan
characteristics, and if any such loans are significant at the 20% level on an individual •1.
July 11, 2024
Page 2
basis. To the extent any loan receivable on an individual basis exceeds 20%, tell us
how you considered Staff Accounting Bulletin Topic 1.I. regarding financial
statements of properties underlying loans.
Please contact Kellie Kim at 202-551-3129 or Mark Rakip at 202-551-3573 if you have
questions regarding comments on the financial statements and related matters. Please contact
Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Ken Betts