June 13, 2012
CONFIDENTIAL SUBMISSION VIA EMAIL | ||
Amendment No. 1 to Draft Registration Statement | Confidential Submission | |
U.S. Securities and Exchange Commission | Pursuant to | |
100 F Street, NE | Title I, Section 106 under the | |
Washington, DC 20549 | Jumpstart Our Business Startups Act | |
and Section 24(b)(2) of the | ||
Securities Exchange Act of 1934 |
Re: Confidential Submission of TriLinc Global Impact Fund, LLC’s Registration Statement on Form S-1 (CIK No. 0001550453)
Ladies and Gentlemen:
On behalf of our client TriLinc Global Impact Fund, LLC, a Delaware limited liability company (the “Company”) and in response to your letter to us dated May 24, 2012, we hereby confidentially submit Amendment No. 1 (“Amendment No. 1”) to Registration Statement on Form S-1 (the “Registration Statement”) of the Company submitted on May 18, 2012, pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act and Section 24(b)(2) of the Securities Exchange Act of 1934 for non-public review by the Staff of the Securities and Exchange Commission prior to the public filing of the Registration Statement. In response to your letter to us, Amendment No. 1 includes a complete set of financial statements, including footnotes and audit opinion. The only other changes contained in Amendment No. 1 include updating of the Exhibit Index to indicate the exhibits previously submitted and updating the date on the cover and signature pages. A copy of the Amendment No. 1 to the Registration Statement is enclosed via this email submission.
If you have any questions with respect to this confidential submission, please call me at 212-801-9330.
Very truly yours, |
Judith D. Fryer, Esq. |
Enclosures
cc: Gloria S. Nelund, Chairman and Chief Executive Officer of the Company
GREENBERG TRAURIG, LLP¡ ATTORNEYS AT LAW¡ WWW.GTLAW.COM
MetLife Building¡ 200 Park Avenue¡ New York, NY 10166¡ Tel 212.801.9200¡ Fax 212.801.6400
UNITED STATES | ||
SECURITIES AND EXCHANGE COMMISSION | ||
WASHINGTON, D.C. 20549 | ||
DIVISION OF CORPORATION FINANCE |
May 24, 2012
Via Secure E-mail
Gloria Nelund
Chairman and Chief Executive Officer
TriLinc Global Impact Fund, LLC
1230 Rosecrans Ave., Suite 605
Manhattan Beach, CA 90266
Re: | TriLinc Global Impact Fund, LLC |
Confidential Draft Registration Statement on Form S-1
Submitted May 18, 2012
CIK No. 0001550453
Dear Ms. Nelund:
Our preliminary review of your confidential draft registration statement indicates that it fails in numerous material respects to comply with the requirements of the form. Please include a complete set of financial statements, including footnotes and audit opinion, in your next amendment.
We will not perform a detailed examination of the confidential draft registration statement and we will not issue comments because to do so would delay the review of other disclosure documents that do not appear to contain material deficiencies.
You may submit a substantive amendment to correct the deficiencies. If you have any questions, please contact the undersigned at (202) 551-3492.
Sincerely, |
/s/ John P. Nolan |
John P. Nolan |
Senior Assistant Chief Accountant |