0001104659-18-046471.txt : 20180822 0001104659-18-046471.hdr.sgml : 20180822 20180723134731 ACCESSION NUMBER: 0001104659-18-046471 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180723 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Focus Financial Partners Inc. CENTRAL INDEX KEY: 0001651052 STANDARD INDUSTRIAL CLASSIFICATION: INVESTMENT ADVICE [6282] IRS NUMBER: 474780811 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 825 THIRD AVENUE STREET 2: 27TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 BUSINESS PHONE: (646)519-2456 MAIL ADDRESS: STREET 1: 825 THIRD AVENUE STREET 2: 27TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 CORRESP 1 filename1.htm

 

Goldman Sachs & Co. LLC
200 West Street
New York, New York 10282-2198

 

Merrill Lynch, Pierce, Fenner & Smith

Incorporated

One Bryant Park
New York, New York 10036

 

July 23, 2018

 

Office of Financial Services

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 

Attn:                    Ms. Erin E. Martin

 

Re:                             Focus Financial Partners Inc.

Registration Statement on Form S-1

Registration File No. 333-225166

 

Ladies and Gentlemen:

 

In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Focus Financial Partners Inc. (the “Company”) for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 4:00 PM, Washington, D.C. time, on July 25, 2018, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Vinson & Elkins L.L.P., request by telephone that such Registration Statement be declared effective.

 

Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated July 16, 2018:

 

(i)                                     Dates of distribution: July 16, 2018 through the date hereof

(ii)                                  Number of prospective underwriters to which the preliminary prospectus was furnished: 12

(iii)                               Number of prospectuses furnished to investors: approximately 785

(iv)                              Number of prospectuses distributed to others, including the Company, the Company’s counsel, independent accountants, and underwriters’ counsel: approximately 148

 


 

We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 

 

 

Very truly yours,

 

 

 

GOLDMAN SACHS & CO. LLC AND

 

MERRILL LYNCH, PIERCE, FENNER

 

INCORPORATED

 

Acting severally on behalf of themselves and the several Underwriters

 

 

 

 

 

By:

GOLDMAN SACHS & CO. LLC

 

 

 

 

 

 

 

 

 

By:

/s/ Erich Bluhm

 

 

Name:

Erich Bluhm

 

 

Title:

Managing Director

 

 

 

By:

MERRILL LYNCH, PIERCE, FENNER & SMITH

 

 

INCORPORATED

 

 

 

 

 

 

 

 

 

By:

/s/ Michael Liloia

 

 

Name:

Michael Liloia

 

 

Title:

Director