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United States securities and exchange commission logo
December 17, 2020
William A. Newman
Chief Executive Officer
Home Point Capital Inc.
2211 Old Earhart Road, Suite 250
Ann Arbor, MI 48105
Re: Home Point Capital
Inc.
Amendment No. 1 to
Draft Registration
Statement on Form S-1
Submitted December
11, 2020
CIK No. 0001830197
Dear Mr. Newman :
We have reviewed your amended draft registration statement 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 providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. 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 the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amended Draft Registration Statement submitted December 11, 2020
Company Overview, page 1
1. Refer to your response
to comment 4. Please briefly describe any limitations that may be
imposed on future
growth by the need to further expand the company's warehouse
facilities, in addition
to any representations, warranties or covenants that would limit such
further growth or limit
the use of the warehouse lines.
Business, page 102
2. We note that you
present several business metrics for the twelve months ended September
30, 2020 or 3Q'20
throughout your filing, including in the Business section, while
William A. Newman
Home Point Capital Inc.
December 17, 2020
Page 2
comparing them to those for the twelve months in 2019. Please address the
following:
Tell us and revise to disclose why this metric provides meaningful
information to an
investor considering that it includes data from the last quarter in
2019;
Revise to also present these metrics for the nine months ended
September 30, 2020 so
that investors can better asses your performance as it compares to
your operating
results presented in the financial statements and in the Management's
Discussion and
Analysis section for the corresponding periods presented; and
Revise to clearly disclose what LTM stands for in each of the graphs
or tables
presented.
3. We also note on pages 105 and 4 that you disclose total net revenue and
total net income
(loss), as well as related non-GAAP metrics, for the twelve months ended
September 30,
2020. Please tell us and revise to disclose where these GAAP based
financial results are
derived from and update your non-GAAP financial measures disclosures and
reconciliations to GAAP accordingly.
You may contact William Schroeder at 202-551-3294 or Amit Pande at
202-551-3423 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Julia Griffith at 202-551-3267 or J. Nolan McWilliams at 202-551-3267
with any other
questions.
Sincerely,
FirstName LastNameWilliam A. Newman
Division of
Corporation Finance
Comapany NameHome Point Capital Inc.
Office of Finance
December 17, 2020 Page 2
cc: Joe Kauffman
FirstName LastName