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November 27, 2023
Richard G. Rodick
Chief Financial Officer
Altisource Asset Management Corp
5100 Tamarind Reef
Christiansted, U.S. Virgin Islands 00820
Re: Altisource Asset
Management Corp
Form 10-K for the
Year Ended December 31, 2022
Filed March 27,
2023
File No. 001-36063
Dear Richard G. Rodick:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Year Ended December 31, 2022
Consolidated Statements of Stockholders' Deficit, page F-8
1. Please include
redeemable preferred stock in the Consolidated Statements of
Stockholders' Deficit
or provide a rollforward of the account in the Notes to Consolidated
Financial Statements.
Note 4. Loans Held for Sale or Investment at Fair Value, page F-18
2. Please expand your
disclosure to include:
the difference
between the aggregate fair value and the aggregate unpaid principal
balance
the aggregate fair
value of loans that are 90 days or more past due
the aggregate fair
value of loans in nonaccrual status
the difference
between the aggregate fair value and the aggregate unpaid principal
balance for loans
that are 90 days or more past due, in nonaccrual status, or both
the estimated
amount of gains or losses included in earnings during the period
Richard G. Rodick
Altisource Asset Management Corp
November 27, 2023
Page 2
attributable to changes in instrument-specific credit risk
how the gains or losses attributable to changes in
instrument-specific credit risk were
determined
Refer to ASC 825-10-50-28 through 50-32.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact William Demarest at 202-551-3432 or Kristina Marrone at
202-551-3429
with any questions.
FirstName LastNameRichard G. Rodick Sincerely,
Comapany NameAltisource Asset Management Corp
Division of
Corporation Finance
November 27, 2023 Page 2 Office of Real
Estate & Construction
FirstName LastName