SEC – ‘UPLOAD’ from 3/17/21 re: 370 Markets LLC – ‘TEXT-EXTRACT’

On:  Wednesday, 3/17/21, at 5:30pm ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed   ·   Accession #:  0-21-3226

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Delayed-Release Comment or Other Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                 PDF     29K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC - PDF's         2±     8K 
                Text                                                             

‘TEXT-EXTRACT’   —   Comment or Other Letter from the SEC – PDF’s Text

United States securities and exchange commission logo                           

March 17, 2021        

Gerome Daren Sapp                                                 
Chief Executive Officer                                           
370 Markets LLC                                                   
8545 W. Warm Springs Road, Ste A4 #192                            
Las Vegas, NV 89113                                               

                                                   Re: 370 Markets LLC
                                                          Amendment No. 2 to
                                                          Offering Statement
on Form 1-A                                                                     
                                                           Filed March 9, 2021
                                                          File No. 024-11383

Dear Mr. Sapp:                                                    

         We have reviewed your amended offering statement and have the
following comment. In                                                           
  our comment, 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 comment applies 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 this comment, we may have additional comments.
Unless we note                                                                  
      otherwise, our references to prior comments are to comments in our March
12, 2021 letter.                                                                

   Amendment No. 2 to Offering Statement on Form 1-A Filed March 9, 2021

Part F/S                                                          
Financial Statements, page 101                                    

1.                                                   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.          
Gerome Daren Sapp                                                             
FirstName  LastNameGerome Daren Sapp                                            
370 Markets  LLC                                                                
Comapany                                                                        
March      Name370 Markets LLC                                                  
17, 2021                                                          
March2 17, 2021 Page 2                                                          
Page                                                                            
FirstName LastName                                                              
    You may contact Stephen Kim at (202) 551-3291 or Rufus Decker at (202)
551-3769 if                                                                     
you have questions regarding comments on the financial statements and related   
matters. Please                                                                 
contact Katherine Bagley at (202) 551-2545 or Dietrich King at (202) 551-8071   
with any other                                                                  
questions.                                                                      

                                              Sincerely,

                                               Division of
Corporation Finance                                                             
                                                     Office of Trade &
Services                                                                        

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Filed on:		3/17/21		UPLOAD
		3/12/21		UPLOAD
		3/9/21		1-A/A,  UPLOAD
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