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SEC Comment Letter 0000000000-23-003419 to Landa Financing LLC (CIK 0001965132)

Landa Financing LLC (CIK 0001965132)
Date: April 5, 2023 · CIK: 0001965132 · Accession: 0000000000-23-003419

AI Filing Summary & Sentiment

File numbers found in text: 024-12193

Date
April 5, 2023
Author
Not clearly detected
Form
UPLOAD
Company
Landa Financing LLC (CIK 0001965132)

Letter

United States securities and exchange commission logo April 5, 2023 Yishai Cohen Chief Executive Officer Landa Financing LLC 6 W. 18th Street, 12th Floor New York, NY 10011 Re:Landa Financing LLC Offering Statement on Form 1-A Filed March 22, 2023 File No. 024-12193 Dear Yishai Cohen: We have reviewed your offering statement 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 this letter by amending your offering statement and providing the requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Offering Statement on Form 1-A filed March 22, 2023 General 1.We note your response to comment 1. However, your disclosure is still unclear regarding when the company plans to price the securities. Please clarify the language stating that for "approximately" one year following the offering commencement the purchase price will be $10 per share and that "on or about" the first day of each quarter the share price will be determined. Also revise the language that your Manager has the "discretion, to adjust the per Share purchase price or specified pricing period (but in no event more frequently than monthly or less frequently than annually)." Signatures, page 107 2.We note your response to comment 2. Please add the signatures for the majority of the members of the company's board of directors. Additionally, please provide the disclosure required by Item 10 of Form 1-A for your principal financial officer.

FirstName LastNameYishai Cohen Comapany NameLanda Financing LLC April 5, 2023 Page 2 FirstName LastName Yishai Cohen Landa Financing LLC April 5, 2023 Page 2 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 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. We also remind you that, following qualification of your Form 1-A, Rule 257 of Regulation A requires you to file periodic and current reports, including a Form 1-K which will be due within 120 calendar days after the end of the fiscal year covered by the report. Please contact Stacie Gorman at 202-551-3585 or Brigitte Lippmann at 202-551- 3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Mark Schonberger, Esq.

Show Raw Text
United States securities and exchange commission logo
April 5, 2023
Yishai Cohen
Chief Executive Officer
Landa Financing LLC
6 W. 18th Street, 12th Floor
New York, NY 10011
Re:Landa Financing LLC
Offering Statement on Form 1-A
Filed March 22, 2023
File No. 024-12193
Dear Yishai Cohen:
            We have reviewed your offering statement 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 this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Offering Statement on Form 1-A filed March 22, 2023
General
1.We note your response to comment 1.  However, your disclosure is still unclear regarding
when the company plans to price the securities. Please clarify the language stating that for
"approximately" one year following the offering commencement the purchase price will
be $10 per share and that "on or about" the first day of each quarter the share price will be
determined. Also revise the language that your Manager has the "discretion, to adjust the
per Share purchase price or specified pricing period (but in no event more frequently than
monthly or less frequently than annually)."
Signatures, page 107
2.We note your response to comment 2.  Please add the signatures for the majority of the
members of the company's board of directors. Additionally, please provide the disclosure
required by Item 10 of Form 1-A for your principal financial officer.

 FirstName LastNameYishai Cohen
 Comapany NameLanda Financing LLC
 April 5, 2023 Page 2
 FirstName LastName
Yishai Cohen
Landa Financing LLC
April 5, 2023
Page 2
            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
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.  We also remind you that, following qualification of your Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.
            Please contact Stacie Gorman at 202-551-3585 or Brigitte Lippmann at 202-551-
3713 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Mark Schonberger, Esq.