SEC Comment Letter for COMPOUND REAL ESTATE BONDS II INC. (CIK 0002078250) — Aug 27, 2025
COMPOUND REAL ESTATE BONDS II INC. (CIK 0002078250)
Date: Aug. 27, 2025 · CIK: 0002078250 · Accession: 0000000000-25-009218
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 024-12644
Letter
August 27, 2025 Inderjit Tuli Chief Executive Officer COMPOUND REAL ESTATE BONDS II INC. 1185 Avenue of the Americas 3rd floor New York, NY 10036 Re:COMPOUND REAL ESTATE BONDS II INC. Amendment No. 1 to Offering Statement on Form 1-A Filed August 14, 2025 File No. 024-12644 Dear Inderjit Tuli: We have reviewed your amended offering statement and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our August 4, 2025, letter. Amendment No. 1 to Offering Statement on Form 1-A Prior Performance, page 57 1.We note your response to prior comment 2 and your revisions on page 57. Please further expand your disclosure to include information regarding the total amount of funds raised and the number of investors. Additionally, we note that CF Disclosure Topic 6 clarifies, in the introduction, that the information called for by Industry Guide 5, as modified by Disclosure Topic 6, applies to entities that invest in real-estate related assets. Please provide the prior performance tables, as appropriately adapted, to account for your assets. Please refer to Industry Guide 5 and CF Disclosure Guidance: Topic No. 6.
August 27, 2025 Page 2 Please contact Stacie Gorman at 202-551-3585 or Pam Howell at 202-551-3357 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Arden Anderson, Esq.
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August 27, 2025
Inderjit Tuli
Chief Executive Officer
COMPOUND REAL ESTATE BONDS II INC.
1185 Avenue of the Americas
3rd floor
New York, NY 10036
Re:COMPOUND REAL ESTATE BONDS II INC.
Amendment No. 1 to Offering Statement on Form 1-A
Filed August 14, 2025
File No. 024-12644
Dear Inderjit Tuli:
We have reviewed your amended offering statement and have the following comment.
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. Unless we note
otherwise, any references to prior comments are to comments in our August 4, 2025, letter.
Amendment No. 1 to Offering Statement on Form 1-A
Prior Performance, page 57
1.We note your response to prior comment 2 and your revisions on page 57. Please
further expand your disclosure to include information regarding the total amount of
funds raised and the number of investors. Additionally, we note that CF Disclosure
Topic 6 clarifies, in the introduction, that the information called for by Industry Guide
5, as modified by Disclosure Topic 6, applies to entities that invest in real-estate
related assets. Please provide the prior performance tables, as appropriately adapted,
to account for your assets. Please refer to Industry Guide 5 and CF Disclosure
Guidance: Topic No. 6.
August 27, 2025
Page 2
Please contact Stacie Gorman at 202-551-3585 or Pam Howell at 202-551-3357 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Arden Anderson, Esq.