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Correspondence 0001193125-22-295558 from ST JOE Co (JOE) (CIK 0000745308) (JOE)

ST JOE Co (JOE) (CIK 0000745308)
Date: Nov. 30, 2022 · CIK: 0000745308 · Accession: 0001193125-22-295558

AI Filing Summary & Sentiment

File numbers found in text: 001-10466

Referenced dates: November 18, 2022

Date
November 30, 2022
Author
/s/ Marek Bakun
Form
CORRESP
Company
ST JOE Co (JOE) (CIK 0000745308)

Letter

Office of Real Estate & Construction Division of Corporation Finance United States Securities and Exchange Commission Form 10-K for the fiscal year ended December 31, 2022 Form 10-Q for the quarterly period ended September 30, 2022 File No. 001-10466

Re: The St. Joe Company

Dear Messrs. McPhee and Lee:

On behalf of The St. Joe Company (the “Company”), we hereby respond to the comment provided by the Staff of the Securities and Exchange Commission (the “Staff”) in its letter dated November 18, 2022 with respect to the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 and the Company’s Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2022. For ease of reference, we have included the Staff’s comment in its entirety in bold text preceding our response.

Form 10-Q for the quarterly period ended September 30, 2022

Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 49

1. In future filings, both in the current period and prospectively, please expand your disclosures to specifically discuss how increased interest rates impact your results of operations and your financial condition.

The Company acknowledges the Staff’s comment and respectfully advises the Staff that it will expand its disclosures in future filings to specifically discuss how increased interest rates impact the Company’s results of operations and financial condition.

Please direct any questions, comments or requests for further information to the undersigned at (850) 231-7407.

Sincerely,
/s/ Marek Bakun

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 November 30, 2022

Office of Real Estate & Construction

 Division of
Corporation Finance

 United States Securities and Exchange Commission

100 F. Street, NE

 Washington, DC 20549-3561

 Re: The St. Joe Company

Form 10-K for the fiscal year ended December 31, 2022

Form 10-Q for the quarterly period ended September 30, 2022

File No. 001-10466

Dear Messrs. McPhee and Lee:

 On behalf of The St. Joe Company
(the “Company”), we hereby respond to the comment provided by the Staff of the Securities and Exchange Commission (the “Staff”) in its letter dated November 18, 2022 with respect to the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 and the Company’s Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2022. For ease of
reference, we have included the Staff’s comment in its entirety in bold text preceding our response.

 Form
10-Q for the quarterly period ended September 30, 2022

 Item 2. Management’s Discussion and
Analysis of Financial Condition and Results of Operations, page 49

 1. In future filings, both in the current period and prospectively, please
expand your disclosures to specifically discuss how increased interest rates impact your results of operations and your financial condition.

 The
Company acknowledges the Staff’s comment and respectfully advises the Staff that it will expand its disclosures in future filings to specifically discuss how increased interest rates impact the Company’s results of operations and financial
condition.

 Please direct any questions, comments or requests for further information to the undersigned at (850)
231-7407.

Sincerely,

 /s/ Marek Bakun

Marek Bakun

Executive Vice President and Chief Financial Officer

Cc:
 Elizabeth J. Walters, Senior Vice

President and General Counsel

Zachary J. Davis, King & Spalding LLP