KENNETH L. BETTS
PARTNER
214-453-6435
kbetts@winston.com
October 23, 2017
CONFIDENTIAL SUBMISSION VIA EDGAR
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, DC 20549
| Re: | Hall Structured Finance II, LLC
Draft Offering Statement on Form 1-A |
Ladies and Gentlemen:
On behalf of Hall Structured Finance II, LLC, a Texas limited liability company (the “Company”), we are submitting a draft Offering Statement on Form 1-A (the “Offering Statement”) to the staff of the Securities and Exchange Commission (“SEC”) for confidential nonpublic review pursuant to Rule 252(d) of Regulation A under the Securities Act of 1933, as amended (the “Securities Act”). The Offering Statement submitted herewith relates to the offering of the Company’s debentures.
We confirm to you that the Company has not previously sold any securities pursuant to a qualified statement under Regulation A or an effective registration statement under the Securities Act.
A formal filing of the Offering Statement will be made at a later date, which in no event will be later than 21 days before qualification of the Offering Statement.
If you have any question sin connection with this filing, please do not hesitate to contact me at (214) 453-6435 or by email atkbetts@winston.com.
| | Sincerely, |
| | |
| | |
| | /s/ Kenneth L. Betts |
KLB/vgb
Enclosures
| cc: | Craig Hall |
| | Mark Blocher |
| | Stephanie Byrd |
