SEC Comment Letter 0000000000-23-010666 to Concreit Series LLC (CIK 0001990419)
Concreit Series LLC (CIK 0001990419)
Date: Sept. 27, 2023 · CIK: 0001990419 · Accession: 0000000000-23-010666
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File numbers found in text: 024-12321
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United States securities and exchange commission logo
September 27, 2023
Sean Hsieh
Chief Executive Officer
Concreit Series LLC
1201 3rd Ave., Suite 2200
Seattle, WA 98101
Re:Concreit Series LLC
Amendment No. 1 to Offering Statement on Form 1-A
Filed September 13, 2023
File No. 024-12321
Dear Sean Hsieh:
We have reviewed your amended 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. Unless we note
otherwise, our references to prior comments are to comments in our September 7, 2023 letter.
Amendment No. 1 to Offering Statement on Form 1-A filed September 13, 2023
General
1.We note your response to comment 1 and reissue in part. Please revise your disclosure on
the prospectus cover page and elsewhere that the "offer and sale of Membership Interests
for each Series shall be made pursuant to a supplement to this Offering Circular, which
shall provide information relating to the Series Property such as the description and
specifications of the Series Property, the acquisition price, and other relevant terms of the
purchase of the Series Property (the “Series Supplement”)." Disclose that you will file an
offering statement or post qualification amendment, as applicable, to register each
separate Series being offered and provide disclosure about each Property relating to a
Series being offered, including financial information.
FirstName LastNameSean Hsieh
Comapany NameConcreit Series LLC
September 27, 2023 Page 2
FirstName LastName
Sean Hsieh
Concreit Series LLC
September 27, 2023
Page 2
2.We note your response to comment 1 and your disclosure that the acquisition of the
property at 7260 Scotlyn Way White House, TN was finalized by Concreit on April 24,
2023 and that it was exclusively funded by cash contributions from the Manager. Please
tell us how you determined audited financial statements of the Series and historical
audited financial statements of the underlying property were not required in the filing.
Include within your response and revise your disclosure to explain whether the property
was purchased by the Manager or its affiliate to be sold to the Series at a later date or
purchased directly by the Series. Further, we note the company’s disclosure in the filing
that states that the property is new construction with no rental history. If the property was
purchased by the Manager, tell us, and disclose if the Manager is currently renting out the
property.
Please contact Kibum Park at 202-551-6836 or Brigitte Lippmann at 202-551-3713 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Saher Hamideh, Esq.