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
_______________________________________________________________________________________
March 18, 2021
Katherine Bagley
United States Securities & Exchange Commission
Division of Corporation Finance
Office of Trade & Services
Washington DC 20549
Re:370 Markets LLC
Offering Statement on Form 1-A Filed December 14, 2020
File No. 024-11383
Dear Ms. Bagley:
Please accept this letter as a response to the Commission’s correspondence to Gerome Daren Sapp, CEO of 370 Markets LLC dated March 17, 2021.
Amendment No. 2 to Offering Statement on Form 1-A Filed March 9, 2021 Part F/S
Financial Statements, page 101
As discussed in our March 9, 2021 phone call, please tell us in greater detail what financial statements you intend to include in your annual and semiannual reports, once you and each Series are capitalized on other than a nominal basis. If the financial statements will reflect 370 Markets, LLC in total and each Series, so state. Also, address whether the audit reports provided will cover 370 Markets, LLC in total and each Series.
Once 370 Markets, LLC and each Series are capitalized on other than a nominal basis, all financial statements required by Regulation A will reflect 370 Markets, LLC in total and each Series and all audit reports provided will cover 370 Markets, LLC in total and each Series. This will include the MD&A sections of all such filings.
We look forward to the Commission’s response and to addressing any further questions or comments or to receiving word that no further comments are forthcoming so qualification may be requested. Thank you.
____________________________________________________________________________________________________________________________
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
Very truly yours,
/s/ Kendall Almerico
Kendall A. Almerico
KAA/kcm
____________________________________________________________________________________________
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
