CORRESP 1 filename1.htm

 

Ladder Capital Corp

345 Park Avenue, 8th Floor

New York, New York 10154

 

July 30, 2015

 

VIA EDGAR

 

Securities and Exchange Commission
Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

Attention: Sara von Althann

 

Re:

Ladder Capital Corp

 

Registration Statement on Form S-3, as amended

 

Initially Filed July 21, 2015

 

File No. 333-205775

 

Ladies and Gentlemen:

 

Ladder Capital Corp (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-3, File No. 333-205775, as amended, to 4:00 p.m., Eastern Time, on Monday, August 3, 2015, or as soon thereafter as practicable.

 

The Company hereby acknowledges its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the above-referenced Registration Statement. In connection with the foregoing request for acceleration of effectiveness, the Company hereby further acknowledges that:

 

·                  should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 

·                  the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 

·                  the Company may not assert staff comments or the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 



 

Please contact Michael Kim of Kirkland & Ellis LLP, special counsel to the Company, at (212) 446-4746, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

 

 

 

Sincerely,

 

 

 

 

 

/s/ Pamela McCormack

 

Pamela McCormack

 

Chief Strategy Officer, General Counsel and
Co-Head of Securitization

 

cc:

Joshua N. Korff, Esq.

 

Michael Kim, Esq.

 

Kirkland & Ellis LLP