SEC Company Response from Shefford Small Business, Inc. (CIK 0002102386) — Apr 1, 2026
Shefford Small Business, Inc. (CIK 0002102386)
Date: April 1, 2026 · CIK: 0002102386 · Accession: 0001477932-26-001918
AI Filing Summary & Sentiment
File numbers found in text: 000-56818
Referenced dates: March 31, 2026
Letter
shefford_corresp.htm
1852 Banking Street
Suite 29551
Greensboro, North Carolina 27408
jcross@sheffordcompanies.com
sheffordcompanies.com
April 1, 2026
VIA EDGAR
Division of Corporation Finance
Office of Real Estate & Construction
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Peter McPhun
Mark Rakip
David Link
Jeffrey Gabor
Re: Shefford Small Business, Inc.
Amendment No. 1 to Registration Statement on Form 10-12G/A
Filed March 16, 2026
File No. 000-56818
Ladies and Gentlemen:
On behalf of Shefford Small Business, Inc. (the “Company”), this letter responds to the Staff’s comment contained in the letter dated March 31, 2026 (the “Comment Letter”) regarding the above-referenced filing. Concurrently with this letter, the Company is filing Amendment No. 2 to the Registration Statement on Form 10-12G (the “Amendment”).
Form 10-12G/A filed on March 16, 2026
Description of Business, page 2
1. We note your response to comment 2 and revised disclosure. Please also briefly state that “in consideration for the 1,000,000 shares, as of the date of this registration statement, Mr. Cross has paid approximately $365 of expenses on behalf of the company”.
Response:
In response to the Staff’s comment, we have revised the “Founder Share Arrangement” disclosure in Item 1, “Description of Business,” on page 2 of the Amendment to state that “In consideration for the 1,000,000 shares, as of the date of this registration statement, Mr. Cross has paid approximately $365 of expenses on behalf of the Company.”
The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the Registration Statement and the Amendment; that Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Registration Statement; and that the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact the undersigned at (646) 330-0977 if you have any questions regarding this response.
Sincerely,
Shefford Small Business, Inc.
Show Raw Text
CORRESP
1
filename1.htm
shefford_corresp.htm
1852 Banking Street
Suite 29551
Greensboro, North Carolina 27408
jcross@sheffordcompanies.com
sheffordcompanies.com
April 1, 2026
VIA EDGAR
Division of Corporation Finance
Office of Real Estate & Construction
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Peter McPhun
Mark Rakip
David Link
Jeffrey Gabor
Re: Shefford Small Business, Inc.
Amendment No. 1 to Registration Statement on Form 10-12G/A
Filed March 16, 2026
File No. 000-56818
Ladies and Gentlemen:
On behalf of Shefford Small Business, Inc. (the “Company”), this letter responds to the Staff’s comment contained in the letter dated March 31, 2026 (the “Comment Letter”) regarding the above-referenced filing. Concurrently with this letter, the Company is filing Amendment No. 2 to the Registration Statement on Form 10-12G (the “Amendment”).
Form 10-12G/A filed on March 16, 2026
Description of Business, page 2
1. We note your response to comment 2 and revised disclosure. Please also briefly state that “in consideration for the 1,000,000 shares, as of the date of this registration statement, Mr. Cross has paid approximately $365 of expenses on behalf of the company”.
Response:
In response to the Staff’s comment, we have revised the “Founder Share Arrangement” disclosure in Item 1, “Description of Business,” on page 2 of the Amendment to state that “In consideration for the 1,000,000 shares, as of the date of this registration statement, Mr. Cross has paid approximately $365 of expenses on behalf of the Company.”
The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the Registration Statement and the Amendment; that Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Registration Statement; and that the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
1
Please contact the undersigned at (646) 330-0977 if you have any questions regarding this response.
Sincerely,
Shefford Small Business, Inc.
By:
/s/ Jonathan Cross
Name:
Jonathan Cross
Title:
Chief Executive Officer
2