0001174947-17-001570.txt : 20171219 0001174947-17-001570.hdr.sgml : 20171219 20171114153701 ACCESSION NUMBER: 0001174947-17-001570 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20171114 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BLUEGREEN VACATIONS CORP CENTRAL INDEX KEY: 0000778946 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE AGENTS & MANAGERS (FOR OTHERS) [6531] IRS NUMBER: 030300793 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4960 CONFERENCE WAY NORTH STREET 2: SUITE 100 CITY: BOCA RATON STATE: FL ZIP: 33431 BUSINESS PHONE: 5619128000 MAIL ADDRESS: STREET 1: 4960 CONFERENCE WAY NORTH STREET 2: SUITE 100 CITY: BOCA RATON STATE: FL ZIP: 33431 FORMER COMPANY: FORMER CONFORMED NAME: BLUEGREEN CORP DATE OF NAME CHANGE: 19960322 FORMER COMPANY: FORMER CONFORMED NAME: PATTEN CORP DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm

 

November 14, 2017

 

VIA EDGAR

 

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C. 20549

Attention: Kim McManus

 

Re:Bluegreen Vacations Corporation

Registration Statement on Form S-1

File No. 333-221062

 

Ladies and Gentlemen,

 

Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended, we wish to advise that between November 7, 2017 and the date hereof, approximately 1,800 copies of the Preliminary Prospectus, dated November 7, 2017, were distributed to prospective underwriters, institutional investors and prospective dealers in connection with the above-captioned Registration Statement.

 

We wish to advise you that the participating underwriters have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 

We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m. (Eastern time) on November 16, 2017, or as soon as practicable thereafter.

 

 

[Signature Page Follows]

 

 

 

 

 

  Very truly yours,
   
  STIFEL, NICOLAUS & COMPANY, INCORPORATED
  CREDIT SUISSE SECURITIES (USA) LLC
   
  As representatives of the Underwriters
   
  STIFEL, NICOLAUS & COMPANY, INCORPORATED
     
     
  By: /s/ Keith Lister                                                          
  Name: Keith Lister
  Title: Managing Director
     
  CREDIT SUISSE SECURITIES (USA) LLC
     
     
  By: /s/ Renos Savvides                                                  
  Name: Renos Savvides
  Title: Director

 

 

 

 

 

[Signature Page to Acceleration Request]