CHAMPION MORTGAGE HOLDINGS CORP.
20 Waterview Boulevard
Parsippany, New Jersey 07054
May 28, 1997
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Re: Champion Mortgage Holdings Corp.
Registration Statement on Form S-1 of 4,025,000 Shares of Common Stock
(Registration No. 333-21513) (The "Registration Statement")
Ladies and Gentlemen:
Reference is hereby made to the above-referenced Registration Statement, which
was filed with the Securities and Exchange Commission (the "Commission") by
Champion Mortgage Holdings Corp. (the "Company") on February 10, 1997 and the
Registration Statements on Forms 8-A and 8-A/A (together with the Registration
Statement, the "Registration Statements") which were submitted in connection
with the Company's proposed initial public offering of its common stock.
Pursuant to Rule 477 under the Securities Act of 1933, as amended, application
is hereby made by the Company to withdraw the Registration Statements. The
Company has determined that, in view of current market conditions, it is
inadvisable to proceed with the registration and sale of its common stock at
this time. In addition, no shares of common stock have been offered or sold
pursuant to the Registration Statements.
The Company requests that the Commission consent to this application on the
grounds that withdrawal of the Registration Statements is consistent with the
public interest and the protection of investors, as contemplated by paragraph
(a) of said Rule 477.
Please provide the Company with a copy of the order granting withdrawal of the
Registration Statements as soon as it is available.
If you have any questions regarding this application, please contact the
Company's legal counsel, James R. Tanenbaum of Stroock & Stroock & Lavan LLP at
(212) 806-6048.
Very truly yours,
CHAMPION MORTGAGE HOLDINGS CORP.
/S/ Daniel L. Rich
Name: Daniel L. Rich
Title: Senior Vice President
cc: Russell H. Bates, Esq.
James R. Tanenbaum, Esq.
