ALMERICO LAW

KENDALL A. ALMERICO P.A.

ATTORNEY AT LAW

 

CROWDFUNDING LAW w JOBS ACT w REGULATION A w REGULATION CF w PRIVATE EQUITY w CORPORATE LAW

_______________________________________________________________________________________

---

August 9, 2021

 

Katherine Bagley

United States Securities & Exchange Commission

Division of Corporation

Office of Trade & Services

Washington DC 20549

 

Re:370 Markets LLC Offering Statement on Form 1-A 

Post-qualification Amendment No. 1

Filed April 26, 2021

File No. 024-11383

 

Dear Ms. Bagley:

 

Please accept this letter and refiling in response to the Commission’s correspondence to Gerome Sapp, CEO of 370 Markets LLC dated July 19, 2021.

 

Post-qualification amendment No. 2 to Offering Statement on Form 1-A

 

General

 

We note your response to comment 1, and your amended financial statements. Please

amend to provide an updated auditor consent. Refer to part 11 of Item 17 of Form 1-A.

As a related matter, it appears that there has been a change in your certifying accountant,

but you did not file a 1-U reporting this change. Therefore, please amend your disclosure

to provide the information required by Item 4 of Form 1-U and, pursuant to part 9 of Item

17, please file a letter from your former independent accountant regarding its concurrence

or disagreement with any disclosure you provide related to the dismissal or resignation of

your former accountant. For guidance, see Rule 252 of Regulation A, which requires

disclosure of material information necessary to make the required statements, in light of

the circumstances under which they are made, not misleading.

 

Form 1-U was filed on 8-9-21 to provide details of the change of certifying accountant. Disclosures have been amended in the Form 1-POS filed on 8-9-21. New auditors’ consent has also been filed on 8-9-21.

---

____________________________________________________________________________________________________________________________

Washington DC Office     1440 G Street NW     Washington DC 20005

        

Cell: (813) 309-6258

Office: (202) 370-1333

E-mail: AlmericoLaw@gmail.com

www.Almerico.com

Member of the Florida Bar

---

We look forward to the Commission’s response and to addressing any further questions or comments.  Thank you.

 

Very truly yours,  

 

/s/ Kendall Almerico 

 

Kendall A. Almerico 

---

____________________________________________________________________________________________

 

ALMERICO LAW

KENDALL A. ALMERICO^, P.A.

ATTORNEYS AT LAW

 

CROWDFUNDING LAW w JOBS ACT w REGULATION A w REGULATION CF w PRIVATE EQUITY w CORPORATE LAW

 

Telephone: (813) 309-6258

E-mail: AlmericoLaw@gmail.com