LADDER CAPITAL FINANCE HOLDINGS LLLP
LADDER CAPITAL FINANCE CORPORATION
345 Park Avenue, 8th Floor
New York, New York
August 30, 2013
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, D.C. 20549
FAX: (202) 772-9202
| Attention: | Mr. Jerard Gibson | |||||
| Re: | Ladder Capital Finance Holdings LLLP and Ladder Capital Finance Corporation (the “Companies”) Registration Statement on Form S-4 (SEC File No. 333-188224) Originally Filed April 30, 2013 | |||||
Ladies and Gentlemen:
The Companies hereby request acceleration of the effective date of their Registration Statement on Form S-4 with respect to themselves of the securities specified therein (SEC File No. 333-188224) to 1:00 p.m., Eastern time, on September 3, 2013 or as soon thereafter as possible.
The Companies hereby acknowledge their responsibilities under the Securities Act of 1933, as amended, and the Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the above-referenced Registration Statement. The Companies hereby further acknowledge that:
| • | should the Commission or the staff, acting pursuant to delegated authority, declare this 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 Companies from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Companies may not assert staff comments and 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 call Michael Kim or Paul Beck of Kirkland & Ellis LLP, counsel to the Companies, at (212) 446-4746 or (212) 446-5999, respectively, as soon as the Registration Statement has been declared effective.
| Very truly yours, | ||||||
| LADDER CAPITAL FINANCE HOLDINGS LLLP | ||||||
| By: | /s/ Pamela McCormack | |||||
| Name: Pamela McCormack | ||||||
| Title: General Counsel | ||||||
| LADDER CAPITAL FINANCE CORPORATION | ||||||
| By: | /s/ Pamela McCormack | |||||
| Name: Pamela McCormack | ||||||
| Title: Secretary | ||||||