COVER 15 filename15.htm

 

Anthony F. Geraci*

Christina L. Geraci

Nema Daghbandan

Kevin S. Kim

Dennis R. Baranowski

 

90 Discovery

Irvine, CA 92618

Tel: (949) 379-2600

Fax: (949) 379-2610

www.geracilawfirm.com

 

90 Discovery

Irvine, California 92618

www.geracilawfirm.com

Melissa C. Martorella

Kyle Niewoehner

Tae K. Kim

Tom Hajda**

Darlene P. Hernandez***

Marisol A. Nagata

Lindsay J. Anderson****

 

Via EDGAR

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

 

February 25, 2021

 

Re:CONCREIT FUND I LLC

DRAFT OFFERING STATEMENT ON FORM 1-A

FILED FEBRUARY 25, 2021

 

To whom it may concern:

 

This letter is submitted on behalf of CONCREIT FUND I LLC (the “Company”) to the Division of Corporate Finance (the “Staff”) of the Securities & Exchange Commission (the “Commission”) in connection with the submission of the Company’s draft of Post Qualification Amendment of the Offering Statement on Form 1-A, as well as other exhibits and documentation provided for review pursuant to Regulation A under the Securities Act of 1933, as amended.

 

For your convenience, we note the following highlights within the Offering Circular:

 

·The Company has retained the services of Dalmore Group, LLC as a registered broker-dealer. Please see page 96 of the Offering Circular and Exhibit 6.3.
·The Company has clarified the business operations with respect to the Company’s lending activities. Please see page 46 of the Offering Circular.
·The Company has adjusted the distribution of excess cash such that it is payable 100% to the Investors. Please see pages 55 and 56, as well as Exhibit 2.2.
·The Company has adjusted the redemption plan in favor of investors such that the investors have higher liquidity for their redemption of capital. Please see page 64 and Exhibit 15.2.
·The Company will file its audited financial statement for the year ending in 2020 in connection with the Post Qualification Amendment.

 

 

  Best Regards,
   
  /s/ Tae K. Kim
   
  Tae K. Kim, Esq.
  Corporate & Securities Division
  Geraci Law Firm.

 

 

*Admitted in Arizona and New Jersey **Admitted in Massachusetts and Rhode Island only ***Admitted in New York ****Admitted in Oregon only