SEC Comment Letter 0000000000-24-008938 to Cloud Title Partners LLC (CIK 0002030863)
Cloud Title Partners LLC (CIK 0002030863)
Date: Aug. 5, 2024 · CIK: 0002030863 · Accession: 0000000000-24-008938
AI Filing Summary & Sentiment
File numbers found in text: 024-12471
Letter
August 5, 2024 Thomas Heimann Co-Manager Cloud Title Partners LLC 200 Central Avenue, 4th Floor Saint Petersburg, FL 33701 Re:Cloud Title Partners LLC Amendment No. 1 to Offering Statement on Form 1-A Offering Statement on Form 1-A Filed August 1, 2024 File No. 024-12471 Dear Thomas Heimann: We have reviewed your amended offering statement and have the following comments. Please respond to this letter by amending your offering statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Amendment No. 1 to Offering Statement on Form 1-A Prior Performance, page 45 1.We note your disclosure on page 36 that Mr. Heimann has operated real estate and title insurance companies in the past. If applicable, please provide prior performance tables for programs with similar investment objectives as those set forth in the offering circular, as required by Item 8 of Industry Guide 5. See Item 7(c) of Part II of Form 1-A. Signatures, page 58 2.Please separately include the signature blocks for you, and for your principal executive officer, principal financial officer, principal accounting officer, and a majority of the members of the board or other governing body. See Instructions 1 and 3 to the Signatures section of Form 1-A.
August 5, 2024 Page 2 Please contact Stacie Gorman at 202-551-3585 or Brigitte Lippmann at 202-551-3713 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Louis Amatucci, Esq.
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August 5, 2024
Thomas Heimann
Co-Manager
Cloud Title Partners LLC
200 Central Avenue, 4th Floor
Saint Petersburg, FL 33701
Re:Cloud Title Partners LLC
Amendment No. 1 to Offering Statement on Form 1-A
Offering Statement on Form 1-A
Filed August 1, 2024
File No. 024-12471
Dear Thomas Heimann:
We have reviewed your amended offering statement and have the following comments.
Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Amendment No. 1 to Offering Statement on Form 1-A
Prior Performance, page 45
1.We note your disclosure on page 36 that Mr. Heimann has operated real estate and title
insurance companies in the past. If applicable, please provide prior performance tables for
programs with similar investment objectives as those set forth in the offering circular, as
required by Item 8 of Industry Guide 5. See Item 7(c) of Part II of Form 1-A.
Signatures, page 58
2.Please separately include the signature blocks for you, and for your principal executive
officer, principal financial officer, principal accounting officer, and a majority of the
members of the board or other governing body. See Instructions 1 and 3 to
the Signatures section of Form 1-A.
August 5, 2024
Page 2
Please contact Stacie Gorman at 202-551-3585 or Brigitte Lippmann at 202-551-3713
with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Louis Amatucci, Esq.