SEC Comment Letter 0000000000-23-004258 to KKR Infrastructure Conglomerate LLC (CIK 0001948056)
KKR Infrastructure Conglomerate LLC (CIK 0001948056)
Date: April 26, 2023 · CIK: 0001948056 · Accession: 0000000000-23-004258
AI Filing Summary & Sentiment
File numbers found in text: 000-56484
Referenced dates: April 21, 2023
Letter
United States securities and exchange commission logo April 26, 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. 3 to Registration Statement on Form 10-12G Filed February 3, 2023 Response Letter dated April 21, 2023 File No. 000-56484 Dear Jason Carss: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Correspondence filed April 21, 2023 Exhibit A, page 4 1.With a view towards disclosure, please provide additional details regarding your calculation of net asset value ("NAV"), including: •the roles your manager and board of directors play in determining your valuation procedures and, specifically, who is ultimately responsible for the calculation of your NAV; •cautionary language on valuation methods and their sensitivity, and a quantitative illustration of the sensitivity of the valuation to a percentage change in one or more key assumptions; and •the relationship between the purchase price of your Infrastructure Assets and the value assigned to the Infrastructure Assets (e.g., disclosure of the cost of your Infrastructure Assets inclusive of capital improvements made).
FirstName LastNameJason Carss Comapany NameKKR Infrastructure Conglomerate LLC April 26, 2023 Page 2 FirstName LastName Jason Carss KKR Infrastructure Conglomerate LLC April 26, 2023 Page 2 With regard to future filings, please confirm that you will provide a comparative breakdown of the components of NAV for comparable period valuations and provide the results of historical NAV calculations. 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. 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 Isabel Rivera at 202-551-3518 or Pam 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
April 26, 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. 3 to Registration Statement on Form 10-12G
Filed February 3, 2023
Response Letter dated April 21, 2023
File No. 000-56484
Dear Jason Carss:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Correspondence filed April 21, 2023
Exhibit A, page 4
1.With a view towards disclosure, please provide additional details regarding your
calculation of net asset value ("NAV"), including:
•the roles your manager and board of directors play in determining your valuation
procedures and, specifically, who is ultimately responsible for the calculation of your
NAV;
•cautionary language on valuation methods and their sensitivity, and a quantitative
illustration of the sensitivity of the valuation to a percentage change in one or more
key assumptions; and
•the relationship between the purchase price of your Infrastructure Assets and the
value assigned to the Infrastructure Assets (e.g., disclosure of the cost of your
Infrastructure Assets inclusive of capital improvements made).
FirstName LastNameJason Carss
Comapany NameKKR Infrastructure Conglomerate LLC
April 26, 2023 Page 2
FirstName LastName
Jason Carss
KKR Infrastructure Conglomerate LLC
April 26, 2023
Page 2
With regard to future filings, please confirm that you will provide a comparative
breakdown of the components of NAV for comparable period valuations and provide the
results of historical NAV calculations.
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.
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 Isabel Rivera at 202-551-3518 or Pam Long at 202-551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Mark Brod