SEC Comment Letter 0000000000-23-000928 to KKR Infrastructure Conglomerate LLC (CIK 0001948056)
KKR Infrastructure Conglomerate LLC (CIK 0001948056)
Date: Jan. 27, 2023 · CIK: 0001948056 · Accession: 0000000000-23-000928
AI Filing Summary & Sentiment
File numbers found in text: 000-56484
Referenced dates: November 23, 2022
Letter
United States securities and exchange commission logo January 27, 2023 Jason Carss General Counsel and Secretary KKR Infrastructure Conglomerate LLC 30 Hudson Yards New York, NY 10001 Re:KKR Infrastructure Conglomerate LLC Amendment No. 2 to Registration Statement on Form 10-12G Response dated December 30, 2022 File No. 000-56484 Dear Jason Carss: We have reviewed your December 30, 2022 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 16, 2022 letter. Response dated December 30, 2022 Share Repurchases, page 14 1.Regarding prior comment 2, we note your statement that you will include information as to the primary valuation method and key assumptions for each asset type in your periodic reports on Forms 10-K and 10-Q. This information should also be provided together with the monthly NAV calculation, including the breakdown of components of NAV, total NAV and NAV per share by class, that determines the transaction price at which shareholders may sell their shares to the company under your share repurchase plan described on page 14. Based on your disclosure on page 16, we understand that you plan to post the calculation of monthly NAV on your website. As requested in prior comment 2 and in comment 7 in our letter dated November 23, 2022, please provide your template for this disclosure, revised to address all of the items referenced in prior comment 2.
FirstName LastNameJason Carss Comapany NameKKR Infrastructure Conglomerate LLC January 27, 2023 Page 2 FirstName LastName Jason Carss KKR Infrastructure Conglomerate LLC January 27, 2023 Page 2 We would not be able to operate our business according to our business plans if we are required to register as an investment company . . . , page 48 2.We note your response to prior comment 1. Please note that we have referred your response to the Division of Investment Management and may have further comments. You may contact Howard Efron at (202) 551-3439 or Kristina Marrone at (202) 551- 3429 if you have questions regarding comments on the financial statements and related matters. Please contact Pamela Long at (202) 551-3765 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Mark Brod
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United States securities and exchange commission logo
January 27, 2023
Jason Carss
General Counsel and Secretary
KKR Infrastructure Conglomerate LLC
30 Hudson Yards
New York, NY 10001
Re:KKR Infrastructure Conglomerate LLC
Amendment No. 2 to Registration Statement on Form 10-12G
Response dated December 30, 2022
File No. 000-56484
Dear Jason Carss:
We have reviewed your December 30, 2022 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 16, 2022 letter.
Response dated December 30, 2022
Share Repurchases, page 14
1.Regarding prior comment 2, we note your statement that you will include information as
to the primary valuation method and key assumptions for each asset type in your periodic
reports on Forms 10-K and 10-Q. This information should also be provided together with
the monthly NAV calculation, including the breakdown of components of NAV, total
NAV and NAV per share by class, that determines the transaction price at which
shareholders may sell their shares to the company under your share repurchase plan
described on page 14. Based on your disclosure on page 16, we understand that you plan
to post the calculation of monthly NAV on your website. As requested in prior comment 2
and in comment 7 in our letter dated November 23, 2022, please provide your template for
this disclosure, revised to address all of the items referenced in prior comment 2.
FirstName LastNameJason Carss
Comapany NameKKR Infrastructure Conglomerate LLC
January 27, 2023 Page 2
FirstName LastName
Jason Carss
KKR Infrastructure Conglomerate LLC
January 27, 2023
Page 2
We would not be able to operate our business according to our business plans if we are required
to register as an investment company . . . , page 48
2.We note your response to prior comment 1. Please note that we have referred your
response to the Division of Investment Management and may have further comments.
You may contact Howard Efron at (202) 551-3439 or Kristina Marrone at (202) 551-
3429 if you have questions regarding comments on the financial statements and related
matters. Please contact Pamela Long at (202) 551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Mark Brod