Correspondence 0001193125-24-011258 from Evergy Missouri West, Inc. (CIK 0001955722)
Evergy Missouri West, Inc. (CIK 0001955722)
Date: Jan. 19, 2024 · CIK: 0001955722 · Accession: 0001193125-24-011258
AI Filing Summary & Sentiment
File numbers found in text: 333-268913
Referenced dates: November 7, 2023
Letter
Via Edgar and Electronic Mail Office of Structured Finance Division of Corporation Finance United States Securities and Exchange Commission Evergy Missouri West Storm Funding I, LLC Amendment No. 1 to Registration Statement on Form SF-1 Filed October 27, 2022 File Nos. 333-268913 and 333-268913-01
Dear Mr. Weidberg and Mr. Sandel:
On behalf of Evergy Missouri West, Inc. (“Evergy Missouri West”) and Evergy Missouri West Storm Funding I, LLC (the “Issuing Entity”, and, together with Evergy Missouri West, the “Registrants”), we submit via EDGAR for review by the staff (the “Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”) the accompanying Amendment No. 2 (including certain exhibits) (“Amendment No. 2”) to the Registrants’ above-referenced Registration Statement on Form SF-1 (the “Registration Statement”), which is being filed simultaneously with this response. Amendment No. 2 reflects the Registrants’ response to the comment received from the Staff contained in the Staff’s letter dated November 7, 2023 (the “Comment Letter”) and certain other updated information. For your convenience, the Registrants are providing to the Staff a supplemental typeset copy of Amendment No. 2 marked to indicate the changes from Part II of the Registration Statement that was filed on October 27, 2023.
The Staff’s comments as reflected in the Comment Letter are reproduced in bold typeface in this letter, and the corresponding responses of the Registrants are shown below each comment.
Mr. Jason Weidberg and Mr. Arthur Sandel
Securities and Exchange Commission
January 19, 2023
Page
Registration Statement on Form SF-1
Part II - Information Not Required in Prospectus
Item 15. Undertakings, page 3
1. Please revise to include the undertaking under Item 512(b) of Regulation S-K or tell us why it is not appropriate for you to do so.
The Registrants have included the undertaking under Item 512(b) of Regulation S-K to Item 15.
* * *
The Registrants acknowledge that: (i) they are responsible for the adequacy and accuracy of the disclosure in the filing; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and (iii) the Registrants may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Thank you for your consideration. If you have any questions concerning the above responses, please do not hesitate to contact the undersigned at (212) 309-1071 or Adam O’Brian, Esq. at Hunton Andrews Kurth LLP.
Sincerely,
/s/ Michael F. Fitzpatrick, Jr., Esq.
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CORRESP
HUNTON ANDREWS KURTH LLP
200 PARK AVENUE
NEW YORK, NY 10166-0005
TEL 212 • 309 • 1000
FAX 212 • 309 • 1100
January 19, 2024
Via Edgar and Electronic Mail
Mr. Jason Weidberg
Mr. Arthur Sandel
Office of Structured Finance
Division of Corporation Finance
United States Securities and Exchange Commission
100 F.
Street N.E.
Washington, DC 20549
Re:
Evergy Missouri West, Inc.
Evergy Missouri West Storm Funding I, LLC
Amendment No. 1 to Registration Statement on Form SF-1
Filed October 27, 2022
File Nos. 333-268913 and
333-268913-01
Dear Mr. Weidberg and Mr. Sandel:
On behalf of Evergy Missouri West, Inc. (“Evergy Missouri West”) and Evergy Missouri West Storm Funding I, LLC (the
“Issuing Entity”, and, together with Evergy Missouri West, the “Registrants”), we submit via EDGAR for review by the staff (the “Staff”) of the Division of Corporation Finance of the United States
Securities and Exchange Commission (the “Commission”) the accompanying Amendment No. 2 (including certain exhibits) (“Amendment No. 2”) to the Registrants’ above-referenced Registration
Statement on Form SF-1 (the “Registration Statement”), which is being filed simultaneously with this response. Amendment No. 2 reflects the Registrants’ response to the comment
received from the Staff contained in the Staff’s letter dated November 7, 2023 (the “Comment Letter”) and certain other updated information. For your convenience, the Registrants are providing to the Staff a supplemental
typeset copy of Amendment No. 2 marked to indicate the changes from Part II of the Registration Statement that was filed on October 27, 2023.
The Staff’s comments as reflected in the Comment Letter are reproduced in bold typeface in this letter, and the corresponding responses
of the Registrants are shown below each comment.
Mr. Jason Weidberg and Mr. Arthur Sandel
Securities and Exchange Commission
January 19, 2023
Page
2
Registration Statement on Form SF-1
Part II - Information Not Required in Prospectus
Item 15. Undertakings, page 3
1.
Please revise to include the undertaking under Item 512(b) of Regulation
S-K or tell us why it is not appropriate for you to do so.
The Registrants
have included the undertaking under Item 512(b) of Regulation S-K to Item 15.
* *
*
The Registrants acknowledge that: (i) they are responsible for the adequacy and accuracy of the
disclosure in the filing; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and (iii) the Registrants may not assert Staff comments
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Thank
you for your consideration. If you have any questions concerning the above responses, please do not hesitate to contact the undersigned at (212) 309-1071 or Adam O’Brian, Esq. at Hunton Andrews Kurth LLP.
Sincerely,
/s/ Michael F. Fitzpatrick, Jr., Esq.
Michael F. Fitzpatrick, Jr., Esq.
cc:
David A. Campbell, Evergy Missouri West, Inc.
Geoffrey T. Ley, Evergy Missouri West Storm Funding I, LLC
Adam O’Brian, Esq., Hunton Andrews Kurth LLP