SEC Comment Letter for FIRST REAL ESTATE INVESTMENT TRUST OF NEW JERSEY, INC. (FREVS) (CIK 0000036840) (FREVS) — May 13, 2013
FIRST REAL ESTATE INVESTMENT TRUST OF NEW JERSEY, INC. (FREVS) (CIK 0000036840)
Date: May 13, 2013 · CIK: 0000036840 · Accession: 0000000000-13-026155
AI Filing Summary & Sentiment
Letter
May 13, 2013 Via U.S. Mail Donald W. Barney President, Treasurer and Chief Financial Officer First Real Estate Investment Trust of New Jersey 505 Main Street Hackensack, N J 07601
Re: First Real Estate Investment Trust of New Jersey Form 10 -K for fiscal y ear ended October 31, 2012 Filed January 14, 2013 File No. 0-25043
Dear Mr. Barney :
We have reviewed your response dated April 11, 2013 an d have the following additional comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide t he requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K for fiscal year ended October 31, 2012
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 21
Liquidity and Capital Resources, page 33
Contractual Obligations, page 34 We note your response to prior comment 5 and are unable to locate your disclosure 1. estimating the annual estimated cash requirements related to interest on outstanding long - term debt. In future periodic filings, please provide an estimate of such amounts and provide us with your proposed disclosure.
Donald W. Barney First Real Estate Investment Trust of New Jersey May 13, 2013 Page 2
Funds from Operations, page 35 We note your response to prior comment 6 and reissue the comment in part. It appears 2. that your proposed disclosure continues to include adjustments to FFO that would appear to differ from FFO as defin ed by NAREIT. For instance, your FFO calculation contains adjustments for Project abandonment costs and Under market lease amortization, among other adjustments not included in the NAREIT FFO definition. Please advise or revise to provide such amounts wi thin Adjusted FFO.
You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at 202.551.3295 if you have questions regarding comments on the financial s tatements and related matters.
Sincerely,
/s/ Jennifer Monick
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May 13, 2013 Via U.S. Mail Donald W. Barney President, Treasurer and Chief Financial Officer First Real Estate Investment Trust of New Jersey 505 Main Street Hackensack, N J 07601 Re: First Real Estate Investment Trust of New Jersey Form 10 -K for fiscal y ear ended October 31, 2012 Filed January 14, 2013 File No. 0-25043 Dear Mr. Barney : We have reviewed your response dated April 11, 2013 an d have the following additional comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide t he requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10 -K for fiscal year ended October 31, 2012 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 21 Liquidity and Capital Resources, page 33 Contractual Obligations, page 34 We note your response to prior comment 5 and are unable to locate your disclosure 1. estimating the annual estimated cash requirements related to interest on outstanding long - term debt. In future periodic filings, please provide an estimate of such amounts and provide us with your proposed disclosure. Donald W. Barney First Real Estate Investment Trust of New Jersey May 13, 2013 Page 2 Funds from Operations, page 35 We note your response to prior comment 6 and reissue the comment in part. It appears 2. that your proposed disclosure continues to include adjustments to FFO that would appear to differ from FFO as defin ed by NAREIT. For instance, your FFO calculation contains adjustments for Project abandonment costs and Under market lease amortization, among other adjustments not included in the NAREIT FFO definition. Please advise or revise to provide such amounts wi thin Adjusted FFO. You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at 202.551.3295 if you have questions regarding comments on the financial s tatements and related matters. Sincerely, /s/ Jennifer Monick Jennifer Monick Senior Staff Accountant