United States securities and exchange commission logo
October 20, 2021
Ezra Levine
Chief Executive Officer
Collectable Sports Assets, LLC
333 Westchester Avenue, Suite W2100
White Plains, NY 10604
Re: Collectable Sports
Assets, LLC
Post-Qualification
Amendment No. 15 to Form 1-A
Filed September 22,
2021
File No. 024-11178
Dear Mr. Levine:
We have reviewed your amendment and have the following comments.
In some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to this letter by amending your offering statement
and providing the
requested information. If you do not believe our comments apply to your
facts and
circumstances or do not believe an amendment is appropriate, please tell
us why in your
response. After reviewing any amendment to your offering statement and
the information you
provide in response to these comments, we may have additional comments.
Post-Qualification Amendment No. 15 to Form 1-A Filed September 22, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operation, page
967
1. We note your disclosure
on page 967 indicates that you have completely sold five (5)
items off the platform.
By contrast, however, your disclosure on page 970 indicates that
you sold two (2)
Underlying Assets during the period ended December 31, 2020 and
sold eight (8)
Underlying Assets during 2021, which suggests that you have sold more
than five items off of
your platform. Please revise to reconcile these inconsistencies.
General
2. Please revise the
filing to include the financial statements required by Part F/S (b)(3)(B)
of Form 1-A. To satisfy
this requirement, consider whether you are eligible to incorporate
by reference your Form
1-SA filed on September 28, 2021. Refer to Part F/S (b)(3)(B) of
Form 1-A and General
Instruction III to Form 1-A.
Ezra Levine
Collectable Sports Assets, LLC
October 20, 2021
Page 2
3. Based upon the legal opinion provided by counsel, we note that you have
added fifty-two
new series interests and continue to offer seven other series interests,
which you describe,
respectively, as the Additional and Amended Series Interests. Please
revise the disclosure
throughout your offering circular to clearly state which offerings have
closed, are
ongoing, are ongoing as revised or are new, so that investors can
appreciate what
securities you are offering at a given point in time. In this regard,
the table at the outset of
the Offering Circular, as well as your Use of Proceeds, do not clearly
state the status of
each series offering.
We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Nicholas Lamparski at 202-551-4695 or Mara Ransom at
202-551-
3264 with any other questions.
Sincerely,
FirstName LastNameEzra Levine
Division of
Corporation Finance
Comapany NameCollectable Sports Assets, LLC
Office of Trade
& Services
October 20, 2021 Page 2
cc: Gary Brown
FirstName LastName