SEC Comment Letter for FIRST REAL ESTATE INVESTMENT TRUST OF NEW JERSEY, INC. (FREVS) (CIK 0000036840) (FREVS) — Jun 10, 2013
FIRST REAL ESTATE INVESTMENT TRUST OF NEW JERSEY, INC. (FREVS) (CIK 0000036840)
Date: June 10, 2013 · CIK: 0000036840 · Accession: 0000000000-13-031445
AI Filing Summary & Sentiment
Letter
June 10, 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 May 28 , 2013 an d have the following additional comment. In our comment, 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 th e requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, 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
Funds from Operations, page 35 We note your response to prior comment two. It appears that your prop osed disclosure 1. does not include an adjustment for FFO from discontinued operations. Thus, it appears that FFO continues to differ from FFO as defined by NAREIT. Please revise your disclosure in future filings and provide us with an example of your propo sed disclosure.
Donald W. Barney First Real Estate Investment Trust of New Jersey June 10, 2013 Page 2
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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June 10, 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 May 28 , 2013 an d have the following additional comment. In our comment, 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 th e requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, 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 Funds from Operations, page 35 We note your response to prior comment two. It appears that your prop osed disclosure 1. does not include an adjustment for FFO from discontinued operations. Thus, it appears that FFO continues to differ from FFO as defined by NAREIT. Please revise your disclosure in future filings and provide us with an example of your propo sed disclosure. Donald W. Barney First Real Estate Investment Trust of New Jersey June 10, 2013 Page 2 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