SEC Comment Letter for Figure Technology Solutions, (FGRS) — Sep 9, 2025
Figure Technology Solutions, Inc.
Date: Sept. 9, 2025 · CIK: 0002064124 · Accession: 0000000000-25-009750
AI Filing Summary & Sentiment
File numbers found in text: 333-289695
Letter
September 9, 2025 Michael Tannenbaum Chief Executive Officer Figure Technology Solutions, Inc. 100 West Liberty Street, Suite 600 Reno, NV 89501 Re:Figure Technology Solutions, Inc. Amendment No. 4 to Registration Statement on Form S-1 Filed September 9, 2025 File No. 333-289695 Dear Michael Tannenbaum: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration 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 registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 5, 2025 letter. Amendment No. 4 to Registration Statement on Form S-1 Figure Connect, page 193 1.We note your response to prior comment 3, as well as your disclosure that the Guarantor Vehicle has a minimum monthly loan commitment and the return on equity target is, at the current market, approximately 16%. With a view towards clarifying the impact of features that limit how much liquidity is provided by the Guarantor Vehicle, such as the minimum monthly loan commitment and return on equity target, please disclose the minimum monthly loan commitment and the approximate percentage of current HELOCs that would be excluded from purchase by the Guarantor Vehicle based on the current return on equity target.
September 9, 2025 Page 2 Please contact Ben Phippen at 202-551-3697 or Cara Lubit at 202-551-5909 if you have questions regarding comments on the financial statements and related matters. Please contact Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Finance cc:Adam J. Gelardi, Esq.
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September 9, 2025
Michael Tannenbaum
Chief Executive Officer
Figure Technology Solutions, Inc.
100 West Liberty Street, Suite 600
Reno, NV 89501
Re:Figure Technology Solutions, Inc.
Amendment No. 4 to Registration Statement on Form S-1
Filed September 9, 2025
File No. 333-289695
Dear Michael Tannenbaum:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration 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 registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our September 5, 2025 letter.
Amendment No. 4 to Registration Statement on Form S-1
Figure Connect, page 193
1.We note your response to prior comment 3, as well as your disclosure that the
Guarantor Vehicle has a minimum monthly loan commitment and the return on equity
target is, at the current market, approximately 16%. With a view towards clarifying
the impact of features that limit how much liquidity is provided by the Guarantor
Vehicle, such as the minimum monthly loan commitment and return on equity target,
please disclose the minimum monthly loan commitment and the approximate
percentage of current HELOCs that would be excluded from purchase by the
Guarantor Vehicle based on the current return on equity target.
September 9, 2025
Page 2
Please contact Ben Phippen at 202-551-3697 or Cara Lubit at 202-551-5909 if you
have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Adam J. Gelardi, Esq.