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Correspondence 0001628280-25-011481 from Amentum Holdings, Inc. (AMTM)

Amentum Holdings, Inc.
Date: March 10, 2025 · CIK: 0002011286 · Accession: 0001628280-25-011481

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File numbers found in text: 333-285663

Date
March 10, 2025
Author
Andrew Chassin
Form
CORRESP
Company
Amentum Holdings, Inc.

Letter

Document BofA Securities, Inc. As representative of the several Underwriters c/o BofA Securities, Inc. One Bryant Park New York, New York 10036 VIA EDGAR March 10, 2025 U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Ms. Cara Wirth Re: Amentum Holdings, Inc. (the “ Company ”) Registration Statement on Form S-1 (File No. 333-285663) Dear Ms. Wirth: Pursuant to Rule 461 of the Rules and Regulations of the U.S. Securities and Exchange Commission (the “ Commission ”) under the Securities Act of 1933, as amended (the “ Securities Act ”), the undersigned, as representative of the several underwriters (collectively, the “ Underwriters ”), of the proposed public offering of the Company’s common stock, hereby joins with the Company’s request that the effective date of the Registration Statement on Form S-1 (File No. 333-285663) (the “ Registration Statement ”) be accelerated so that the same will be declared effective at 5:00 p.m., Eastern Time, on March 11, 2025, or as soon thereafter as is practicable. Pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act, we wish to advise you that as of the date hereof we expect to distribute as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus to prospective Underwriters, institutional investors, dealers and others. The undersigned, as representative of the several Underwriters, advises that it has complied and will continue to comply, and that it has been informed by the participating Underwriters and dealers that they have complied and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [ Remainder of Page Intentionally Left Blank ] Very truly yours, As Representative of the several Underwriters BOFA SECURITIES, INC. By: /s/ Andrew Chassin Name: Andrew Chassin Title: Managing Director [Signature Page to Acceleration Request by Underwriters]

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CORRESP
 1
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 Document BofA Securities, Inc. As representative of the several Underwriters c/o BofA Securities, Inc. One Bryant Park New York, New York 10036 VIA EDGAR March 10, 2025 U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Ms. Cara Wirth Re:      Amentum Holdings, Inc. (the “ Company ”)  Registration Statement on Form S-1 (File No. 333-285663)  Dear Ms. Wirth: Pursuant to Rule 461 of the Rules and Regulations of the U.S. Securities and Exchange Commission (the “ Commission ”) under the Securities Act of 1933, as amended (the “ Securities Act ”), the undersigned, as representative of the several underwriters (collectively, the “ Underwriters ”), of the proposed public offering of the Company’s common stock, hereby joins with the Company’s request that the effective date of the Registration Statement on Form S-1 (File No. 333-285663) (the “ Registration Statement ”) be accelerated so that the same will be declared effective at 5:00 p.m., Eastern Time, on March 11, 2025, or as soon thereafter as is practicable. Pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act, we wish to advise you that as of the date hereof we expect to distribute as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus to prospective Underwriters, institutional investors, dealers and others. The undersigned, as representative of the several Underwriters, advises that it has complied and will continue to comply, and that it has been informed by the participating Underwriters and dealers that they have complied and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [ Remainder of Page Intentionally Left Blank ] Very truly yours, As Representative of the several Underwriters BOFA SECURITIES, INC. By: /s/ Andrew Chassin   Name: Andrew Chassin   Title: Managing Director [Signature Page to Acceleration Request by Underwriters]