SEC Comment Letter 0000000000-24-001115 to COMPOUND REAL ESTATE BONDS INC (CIK 0001919204)
COMPOUND REAL ESTATE BONDS INC (CIK 0001919204)
Date: Jan. 29, 2024 · CIK: 0001919204 · Accession: 0000000000-24-001115
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File numbers found in text: 024-11848
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United States securities and exchange commission logo
January 29, 2024
Inderjit Tuli
Chief Executive Officer
Compound Real Estate Bonds, Inc.
1185 Avenue of the Americas, 3rd Floor
New York, NY 10036
Re:Compound Real Estate Bonds, Inc.
Post-Qualification Amendment No. 4 to
Offering Statement on Form 1-A
Filed January 12, 2024
File No. 024-11848
Dear Inderjit Tuli:
We have reviewed your amendment and have the following comments.
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.
Post-Qualification Amendment No. 4 to Offering Statement on Form 1-A
Operations - Administrative Services Agreement with Compound Administrative, page 44
1.Please refer to prior comment 4. Since you initially entered into the Administrative
Services Agreement with Compound Administrative Services LLC (“CAS”) on March 17,
2022, please tell us and revise your filing to clearly disclose if CAS incurred any expenses
on your behalf during the year ended December 31, 2022 along with an explanation of
where these expenses are reflected in your financial statements, if applicable.
Exhibits
2.We note your statement on page 44 that you amended the Administrative Services
Agreement on January 12, 2024. Please file the amendment as an exhibit to this offering
statement. Refer to Item 17 of Form 1-A.
We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FirstName LastNameInderjit Tuli
Comapany NameCompound Real Estate Bonds, Inc.
January 29, 2024 Page 2
FirstName LastName
Inderjit Tuli
Compound Real Estate Bonds, Inc.
January 29, 2024
Page 2
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
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.
Please contact Shannon Davis at 202-551-6687 or John Spitz at 202-551-3484 if you
have questions regarding comments on the financial statements and related matters. Please
contact Robert Arzonetti at 202-551-8819 or Tonya Aldave at 202-551-3601 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Arden Anderson, Esq.