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Apollo Global Management, Inc.
CIK: 0001858681  ·  File(s): 333-286493  ·  Started: 2025-04-17  ·  Last active: 2025-05-12
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2025-04-17
Apollo Global Management, Inc.
File Nos in letter: 333-286493
CR Company responded 2025-05-12
Apollo Global Management, Inc.
Offering / Registration Process
File Nos in letter: 333-286493
Apollo Global Management, Inc.
CIK: 0001858681  ·  File(s): 333-255858  ·  Started: 2021-06-03  ·  Last active: 2021-11-02
Response Received 2 company response(s) High - file number match
UL SEC wrote to company 2021-06-03
Apollo Global Management, Inc.
File Nos in letter: 333-255858
Summary
Generating summary...
CR Company responded 2021-07-08
Apollo Global Management, Inc.
File Nos in letter: 333-255858
References: June 3, 2021
Summary
Generating summary...
CR Company responded 2021-11-02
Apollo Global Management, Inc.
File Nos in letter: 333-255858
Summary
Generating summary...
DateTypeCompanyLocationFile NoLink
2025-05-12 Company Response Apollo Global Management, Inc. DE N/A
Offering / Registration Process
Read Filing View
2025-04-17 SEC Comment Letter Apollo Global Management, Inc. DE 333-286493 Read Filing View
2021-11-02 Company Response Apollo Global Management, Inc. DE N/A Read Filing View
2021-07-08 Company Response Apollo Global Management, Inc. DE N/A Read Filing View
2021-06-03 SEC Comment Letter Apollo Global Management, Inc. DE N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2025-04-17 SEC Comment Letter Apollo Global Management, Inc. DE 333-286493 Read Filing View
2021-06-03 SEC Comment Letter Apollo Global Management, Inc. DE N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2025-05-12 Company Response Apollo Global Management, Inc. DE N/A
Offering / Registration Process
Read Filing View
2021-11-02 Company Response Apollo Global Management, Inc. DE N/A Read Filing View
2021-07-08 Company Response Apollo Global Management, Inc. DE N/A Read Filing View
2025-05-12 - CORRESP - Apollo Global Management, Inc.
CORRESP
 1
 filename1.htm

 CORRESP

 APOLLO GLOBAL MANAGEMENT, INC.
 9 West 57th Street, 42nd Floor New
York, New York 10019 May 12, 2025
 VIA EDGAR U.S. Securities and Exchange Commission
 Division of Corporation Finance Office of Finance
 100 F Street, N.E. Washington, D.C. 20549
 Attention: Mr. Robert Arzonetti

 RE:
 Apollo Global Management, Inc.
 Registration Statement on Form S-4
 File No. 333-286493
 Request for Effectiveness Dear Mr.
Arzonetti: Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the
above-captioned Registration Statement on Form S-4 (the “Registration Statement”) filed by Apollo Global Management, Inc. (the “Company”) with the U.S. Securities and Exchange Commission
(the “Commission”) on April 11, 2025, as amended on May 12, 2025, be accelerated to May 14, 2025 at 4:00 p.m. Eastern Time or as soon thereafter as may be practicable.
 We understand that the staff of the Division of Corporate Finance of the Commission will consider this request as confirmation by the Company
of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. It would be appreciated if, as soon as the Registration Statement is declared
effective, you would so inform Christodoulos Kaoutzanis of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3445, with written confirmation sent to the address listed on the cover of the
Registration Statement. Please contact Mr. Kaoutzanis with any questions regarding the foregoing. *****

 Very truly yours,

 By:

 /s/ Jessica Lomm

 Name: Jessica Lomm

 Title: Vice President and Secretary
2025-04-17 - UPLOAD - Apollo Global Management, Inc. File: 333-286493
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 17, 2025

Marc Rowan
Chief Executive Officer
Apollo Global Management, Inc.
9 West 57th Street, 42nd Floor
New York, NY 10019

 Re: Apollo Global Management, Inc.
 Registration Statement on Form S-4
 Filed April 11, 2025
 File No. 333-286493
Dear Marc Rowan:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Robert Arzonetti at 202-551-8819 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Ian Hazlett
</TEXT>
</DOCUMENT>
2021-11-02 - CORRESP - Apollo Global Management, Inc.
CORRESP
1
filename1.htm

TANGO HOLDINGS, INC.

9 West 57th Street 43rd
Floor

New York, New York 10019

November
2, 2021

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mr. David Lin.

Tango Holdings, Inc.

Registration Statement on Form S-4

File No. 333-255858

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act
of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-4, as amended (the
“S-4”) be accelerated to November 4, 2021 at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable.

Please contact Catherine Goodall (212-373-3919) of
Paul, Weiss, Rifkind, Wharton & Garrison LLP with any questions you may have regarding this request. In addition, please notify Ms.
Goodall by telephone when this request for acceleration has been granted.

  Tango Holdings, Inc.

  By:
  /s/ John J. Suydam

  Name:
  John J. Suydam

  Title:
  President and Director
2021-07-08 - CORRESP - Apollo Global Management, Inc.
Read Filing Source Filing Referenced dates: June 3, 2021
CORRESP
1
filename1.htm

CORRESP

 Paul, Weiss, Rifkind, Wharton & Garrison LLP

1285 Avenue of the Americas

 New
York, New York 10019-6064

 July 8, 2021

VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 Office of Finance

100 F Street, N.E.

 Washington, D.C. 20549

Attention:
  David Lin

Eric Envall

 Robert Klein

Hugh West

 Division of Corporate
Finance

 Office of Finance

Re:
 Tango Holdings, Inc.

Registration Statement on Form S-4

Filed May 7, 2021

File No. 333-255858

Ladies and Gentlemen:

 On behalf of Tango
Holdings, Inc. (the “Registrant”) we are writing to respond to the comments set forth in the comment letter of the staff of the Securities and Exchange Commission (the “Staff”) dated June 3, 2021 (the
“Comment Letter”) relating to the above-referenced Registration Statement. The Registrant has revised the Registration Statement in response to the Staff’s comments, and, concurrently with delivery of this letter, filed with
the Securities and Exchange Commission an amendment to the Registration Statement which reflects these revisions and generally updates certain information in the Registration Statement.

To assist your review, set forth below in bold are the comments of the Staff contained in the Comment Letter and immediately below each
comment is the response of the Registrant with respect thereto or a statement identifying the location in the Registration Statement of the requested disclosure or revised disclosure. Please note that all references to page numbers in our responses
refer to the page numbers of Amendment No. 1 (“Amendment No. 1”) to the above-referenced Registration Statement. Capitalized terms used but not defined herein have the meanings ascribed to such terms in the
Registration Statement.

 Registration Statement on Form S-4

The Mergers

 AGM Unaudited Financial
Projections, page 158

1.
 We note the statement at the bottom of page 160 that “AGM’s stockholders are cautioned not to
place undue, if any, reliance on the AGM Supplied Financial Projections.” Please delete the words “if any.”

The Company acknowledges the Staff’s comment and has revised the Registration Statement in response to the Staff’s comment. Please
see page 162 of Amendment No. 1.

 Board of Directors and Management After the Mergers, page 175

2.
 We note your disclosure that James Belardi will become a director of HoldCo upon closing of the mergers.
Please file the written consent of Mr. Belardi as required by Securities Act Rule 438.

 The Company
acknowledges the Staff’s comment and the Consent of Mr. Belardi has been filed with Amendment No. 1 as Exhibit 99.5.

 Material Tax
Consequences of the Mergers

 U.S. Federal Income Tax Consequences of the Mergers Generally, page 324

3.
 We note your disclosure that the tax opinions you describe in this section will be given prior to closing.
We also note that your exhibit index does not provide for any tax opinions. Please confirm that you will file the required opinions regarding tax matters or tell us why you believe such opinions are not required. Refer to Item 601(b)(8) of
Regulation S-K and Section III.A of Staff Legal Bulletin No. 19.

 The
Company acknowledges the Staff’s comment and has added the forms of opinions regarding tax matters to the exhibit index and has filed the forms of the opinions with this Amendment No. 1.

Unaudited Pro Forma Condensed Combined Financial Information

8. Adjustments to Unaudited Pro Forma Condensed Combined Statement of Operations

(N) Adjustments to recalculate the Pro Forma Earnings Per Share, page 359

4.
 We note your presentation and computation of pro forma earnings per share. Please revise your disclosures to
provide greater clarity into the pro forma adjustments made to the historical shares outstanding in order to recompute the 568.3 million pro forma Class A Common Stock shares outstanding, basic and diluted. To the extent that incremental
or share adjustments relate to different steps (e.g., AOG conversion, Transaction Accounting, etc.), disaggregate to show the impact to the denominator associated with each step.

The Company acknowledges the Staff’s comment and has revised the Registration Statement in response to the Staff’s comment. Please
see page 374 of Amendment No. 1.

 *****

If the Staff has any questions concerning this response letter or requires further information, please do not hesitate to contact the undersigned at (212) 373-3919.

 2

Very truly yours,

/s/ Catherine L. Goodall

Catherine L. Goodall

cc:
 Securities and Exchange Commission

David Lin

 Eric Envall

Robert Klein

 Hugh West

Tango Holdings, Inc.

 John J.
Suydam

 Paul, Weiss, Rifkind, Wharton & Garrison LLP

Christodoulos Kaoutzanis, Esq.

 3
2021-06-03 - UPLOAD - Apollo Global Management, Inc.
United States securities and exchange commission logo
June 3, 2021
John J. Suydam
President and Director
Tango Holdings, Inc.
c/o Apollo Global Management, Inc.
9 West 57th Street, 43rd Floor
New York, NY 10019
Re:Tango Holdings, Inc.
Registration Statement on Form S-4
Filed May 7, 2021
File No. 333-255858
Dear Mr. Suydam:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form S-4
The Mergers
AGM Unaudited Financial Projections, page 158
1.We note the statement at the bottom of page 160 that "AGM’s stockholders are cautioned
not to place undue, if any, reliance on the AGM Supplied Financial Projections."  Please
delete the words “if any.”
Board of Directors and Management After the Mergers, page 175
2.We note your disclosure that James Belardi will become a director of HoldCo upon
closing of the mergers.  Please file the written consent of Mr. Belardi as required by
Securities Act Rule 438.

 FirstName LastNameJohn J. Suydam
 Comapany NameTango Holdings, Inc.
 June 3, 2021 Page 2
 FirstName LastName
John J. Suydam
Tango Holdings, Inc.
June 3, 2021
Page 2
Material Tax Consequences of the Mergers
U.S. Federal Income Tax Consequences of the Mergers Generally, page 324
3.We note your disclosure that the tax opinions you describe in this section will be
given prior to closing.  We also note that your exhibit index does not provide for any tax
opinions.  Please confirm that you will file the required opinions regarding tax matters or
tell us why you believe such opinions are not required. Refer to Item 601(b)(8) of
Regulation S-K and Section III.A of Staff Legal Bulletin No. 19.
Unaudited Pro Forma Condensed Combined Financial Information
8. Adjustments to Unaudited Pro Forma Condensed Combined Statement of Operations
(N) Adjustments to recalculate the Pro Forma Earnings Per Share, page 359
4.We note your presentation and computation of pro forma earnings per share. Please revise
your disclosures to provide greater clarity into the pro forma adjustments made to the
historical shares outstanding in order to recompute the 568.3 million pro forma Class A
Common Stock shares outstanding, basic and diluted. To the extent that incremental or
share adjustments relate to different steps (e.g., AOG conversion, Transaction Accounting,
etc.), disaggregate to show the impact to the denominator associated with each step.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Robert Klein at (202) 551-3847 or Hugh West at (202) 551-3872 if you
have questions regarding comments on the financial statements and related matters.  Please
contact David Lin at (202) 551-3552 or Eric Envall at (202) 551-3234 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance