SEC Comment Letter for BRT Apartments Corp. (BRT) (CIK 0000014846) (BRT) — Aug 26, 2016
BRT Apartments Corp. (BRT) (CIK 0000014846)
Date: Aug. 26, 2016 · CIK: 0000014846 · Accession: 0000000000-16-090215
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-213162
Letter
Mail Stop 3233 August 26, 2016 Jeffrey A. Gould President and Chief Executive Officer BRT Realty Trust 60 Cutter Mill Road Great Neck, New York, 11021
Re: BRT Realty Trust Registration Statement on Form S-3 Filed August 16, 2016 File No. 333-213162
Dear Mr. Gould :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h 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 company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and
the company 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 refer to Rules 460 and 4 61 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation
Jeffrey A. Gould BRT Realty Trust August 26, 2016 Page 2
of the fact that those requesting acceleration are aware of their respective responsibilities u nder the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
Please contact me at (202) 551 -6431 with any questions.
Sincerely,
/s/ Nicole Collings
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Mail Stop 3233 August 26, 2016 Jeffrey A. Gould President and Chief Executive Officer BRT Realty Trust 60 Cutter Mill Road Great Neck, New York, 11021 Re: BRT Realty Trust Registration Statement on Form S-3 Filed August 16, 2016 File No. 333-213162 Dear Mr. Gould : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h 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 company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and the company 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 refer to Rules 460 and 4 61 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation Jeffrey A. Gould BRT Realty Trust August 26, 2016 Page 2 of the fact that those requesting acceleration are aware of their respective responsibilities u nder the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . Please contact me at (202) 551 -6431 with any questions. Sincerely, /s/ Nicole Collings Nicole Collings Staff Attorney Office of Real Estate & Commodities cc: S. Asher Gaffney, Esq. BRT Realty Trust