[Letterhead of Wachtell, Lipton, Rosen & Katz]
October 15, 2020
VIA EDGAR AND
FEDERAL EXPRESS
Ms. Tonya K. Aldave
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549-7010
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Re: |
Guild Holdings Company |
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Amendment No. 1 to Registration Statement on Form S-1
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Dear Ms. Aldave:
On behalf of Guild Holdings Company, a Delaware corporation (the “Company”), we are submitting this letter
in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated October 14, 2020 (the “Comment Letter”) relating to
the above-referenced submission and the above-referenced Registration Statement on Form S-1 (the “Registration Statement”). The Company is concurrently filing Amendment No. 2 to the
Registration Statement (“Amendment No. 2”) via EDGAR, and a courtesy copy of Amendment No. 2 marked to show changes to the Registration Statement is being sent to the Staff under separate cover.
For the convenience of the Staff, each of the Staff’s comments is reproduced below in bold and is followed by the
corresponding response of the Company. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in Amendment No. 2. All page references in the responses set forth below refer to pages of Amendment No. 2.
Recent Developments, page 15
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Please update the disclosure regarding the percentage of loans in your service portfolio that have
elected the forbearance option as of the most recent practicable date. |
Response: In
response to the Staff’s comment, pages 15 and 72 of Amendment No. 2 have been revised to address the Staff’s comment.
Non-GAAP Financial Measures, page 77
| 2. |
We note your response to prior comment 2. Please address the following:
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Disclose that you have presented Non-GAAP indicators for the
twelve months ended June 30, 2020 and June 30, 2019 because it provides the most current twelve-month-period data that is available for comparison against historical annual metrics
disclosed. Refer to Item 10(e)(1)(i) of Regulation S-K; and |
Response: In response to the Staff’s comment, pages 25 and 78 of Amendment No. 2 have been revised to
address the Staff’s comment.
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Disclose throughout the registration statement, as applicable, that LTM Q2 2020 represents the last
twelve months ending June 30, 2020. |
Response: In
response to the Staff’s comment, pages 3, 6, 69, 112, 114, 115, 121, 122 and 125 of Amendment No. 2 have been revised to address the Staff’s comment.
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