Erin E. Martin
Legal Branch Chief
Office of Real Estate and Commodities
Division of Corporation Finance
Securities and Exchange Commission
Washington, DC 20549
October 19, 2018
| Re: | REITless Impact Income Strategies LLC |
Amendment No. 1 to
Offering Statement on Form 1-A
Filed October 10, 2018
File No. 024-10891
Dear Ms. Martin:
We acknowledge receipt of the Staff’s comment on October 19, 2018 regarding Amendment No. 1 to the Offering Statement of REITless Impact Income Strategies LLC (the “Company”), which we have set out below, together with our response.
1. We note that you have included a waiver of jury trial provision in your subscription agreement and provided disclosure regarding its impact in risk factor disclosure on page 51. Please also clarify whether purchasers of interests in a secondary transaction would be subject to jury trial waiver provision. Please also affirmatively state in both the offering circular and subscription agreement that by agreeing to the provision, investors will not be deemed to have waived the company’s compliance with the federal securities laws and the rules and regulations promulgated thereunder.
The Company has revised the Offering Circular and the subscription agreement as requested by the Staff.
If you have additional comments or questions, please contact me at jeanne@crowdchecklaw.com.
Sincerely,
/s/ Jeanne Campanelli
Jeanne Campanelli
Partner
CrowdCheck Law LLP
| cc: | James P. Dowd |
REITless Impact Income Strategies LLC