Correspondence 0001641172-25-008313 from Roots Real Estate Investment Community I, LLC (CIK 0001866803)
Roots Real Estate Investment Community I, LLC (CIK 0001866803)
Date: May 2, 2025 · CIK: 0001866803 · Accession: 0001641172-25-008313
AI Filing Summary & Sentiment
File numbers found in text: 024-11897
Referenced dates: May 2, 2025
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CORRESP
1
filename1.htm
May
2, 2025
VIA
EDGAR
Division
of Corporation Finance
Office
of Real Estate & Construction
Securities
and Exchange Commission
100
F Street, NE
Washington,
DC 20549
Re:
Roots
Real Estate Investment Community I, LLC
Post-Qualification
Amendment No. 8 to Offering Statement on Form 1-A
Filed
April 28, 2025
File
No. 024-11897
To
Whom it May Concern:
This
letter is being submitted on behalf of Roots Real Estate Investment Community I, LLC (File No. 024-11897) (the “Company”)
in response to comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
set forth in the Commission’s letter dated May 2, 2025 (the “Comment Letter”) regarding the Company’s
Post-Qualification Amendment No. 8 to its Offering Statement on Form 1-A (the “Initial Filing”) filed with the Commission
on April 28, 2025 in connection with its offering of units pursuant to Regulation A (the “Offering”). The Company
is concurrently filing Post-Qualification Amendment No. 9 to its Offering Statement on Form 1-A (the “Amended Filing”),
which includes changes in response to the Staff’s comments.
For
your convenience, the Staff’s numbered comments set forth in the Comment Letter have been reproduced herein with responses immediately
following each comment. Unless otherwise indicated, page references in the descriptions of the Staff’s comments refer to the Initial
Filing, and page references in the responses, if any, refer to the Amended Filing. Defined terms used herein but not otherwise defined
have the meanings given to them in the Amended Filing.
Real
Estate Portfolio, page 49
Comment
No. 1: We acknowledge your response to prior comment 1 and reissue. To provide further clarity and context for investors, please disclose
the occupancy rate and average effective annual rent on a group basis similarly to your other grouped disclosure provided.
Response:
The Company has updated the “Real Estate Portfolio” section in the Amended Filing to add additional disclosure regarding
the occupancy rate and average effective annual rent in response to the Staff’s comment, and respectfully requests that the Staff
clear this comment.
Thank
you for your consideration of the Company’s response to the Staff’s comments. We appreciate your review and assistance. The
Company respectfully requests that the Staff clear this remaining comment based on the Company’s response herein and the related
updates in the Amended Filing and consider qualifying the Amended Offering as soon as possible. If you have any questions regarding this
response, please do not hesitate to contact the undersigned at mike@williamsbusinesslaw.com or 470-567-3411.
Sincerely
yours,
Williams
Business Law, LLC
Michael
P. Williams
cc:
Larry
Dorfman
Daniel
Dorfman