EF Hutton America, Inc.
77 Water Street, 7th Floor
New York, NY 10005
March 2, 2016
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re:
E.F. Hutton America, Inc.
Form 10-K/A for the Fiscal Year Ended December 31, 2014
Filed February 18, 2016
Forms 10-Q for the Quarterly Period Ended March 31, June 30 and September 30,
2015
Filed May 21, September 21, and November 23, 2015
File No. 000-55175
Dear Sir or Madam:
In response to your comment letter dated February 24, 2016, please note the following:
Form 10-K/A for the Fiscal Year Ended December 31, 2014
Financial Statements
Notes to Consolidated Financial Statements
Note 6 – Intangible Assets, page 28
1. Please amend your filing to disclose, as indicated in your November 3, 2015 letter, that the only material asset you acquired was the license to use the EF Hutton name that has an indefinite useful life.
The disclosure has been amended to state: “On November 25, 2014, the Company purchased certain assets from EFH Group, Inc., a Wyoming corporation. The license to use the EF Hutton name was the only material asset purchased. This license has an indefinite useful life.
Note 11 – Restatement, page 29
2. You refer to the restatements as corrections of typographical errors that were not previously included in an electronic version originally filed on April 15, 2015. Please amend your filing to describe the nature of each error included in the current restatement.
The footnote was revised for clarity. As discussed in the explanatory note, the restatements were made solely to restate the carrying value of the assets acquired on November 25, 2014 to reflect the seller’s carrying value because the transaction is deemed an affiliate transaction.
Forms 10-Q for the Quarterly Periods Ended March 31, June 30 and September 30, 2015
3. Please file amendments to the each Form 10-Q to reflect the revised value of the assets acquired from EFH Wyoming. Address the comments above, as applicable, therein. Also when amending your Form 10-Q for the quarterly period ended March 31, 2015, describe the nature of and effect of the error related to the restatement for the stock-based compensation.
The Form 10-Qs for each period will be amended to reflect the required changes.
Very truly yours,
/s/Christopher Daniels
Christopher Daniels
Chief Executive Officer
EF Hutton America, Inc.
