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May 8, 1997
Via EDGAR and Facsimile
- -----------------------
Securities and Exchange Commission
Division of Corporation Finance
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: Edward M. Kelly
Mail Stop 7-2
Re: EquiVantage Acceptance Corp. Registration Statement on Form
S-3 (File No. 333-22343)
Ladies and Gentlemen:
Reference is made to the captioned registration statement filed with the
Commission on February 25, 1997, as amended by Amendment No. 1 thereto
("Amendment No. 1") filed with the Commission on May 5, 1997. The Registrant
hereby amends the registration statement on such date or dates as may be
necessary to delay its effective date until the Registrant shall file a
further amendment which specifically states that the registration statement
shall thereafter become effective in accordance with Section 8(a) of the
Securities Act of 1933 or until the registration statement shall become
effective on such date as the Commission acting pursuant to said Section
8(a), may determine.
Pursuant to the requirements of the Securities Act of 1933, as amended,
the Registrant certifies that it has reasonable grounds to believe that it
meets all of the requirements for filing on Form S-3 (notwithstanding the
fact that a security rating pursuant to Transaction Requirement B.5. has not
yet been obtained, which security rating requirement, in the reasonable
belief of the Registrant, will be met by the time of any sale) and has duly
caused this Amendment to the Registration Statement to be signed on its
behalf by the undersigned, thereunto duly authorized, in the City of Houston,
State of Texas, on May 8, 1997.
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Securities and Exchange Commission
May 8, 1997
Page 2
EQUIVANTAGE ACCEPTANCE CORP.
By: /s/ John E. Smith
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John E. Smith
President
Pursuant to the requirements of the Securities Act of 1933, as amended,
this Amendment to the Registration Statement has been signed below by the
following persons in the capacities and on the dates indicated.
Signature Title Date
- -------------------- ----- ----
/s/ John E. Smith President (Principal Executive May 8, 1997
- ------------------ Officer) and Director
John E. Smith
* Senior Vice President, May 8, 1997
- ------------------ General Counsel, Secretary
Karen S. Crawford and Director
* Senior Vice President and May 8, 1997
- ------------------ Chief Financial Officer
Elizabeth Folk (Principal Financial Officer
and Principal Accounting
Officer)
* Director May 8, 1997
- ------------------
James Tang
- ------------------ Director May 8, 1997
Don R. Ivey
- ------------------ Director May 8, 1997
Jerry Swank
*By: /s/ John E. Smith
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John E. Smith
Attorney-in-Fact
cc: James A. Blalock III
Hu A. Benton
Christine Bianchine
