SEC Comment Letter for WELLTOWER INC. (WELL) (CIK 0000766704) (WELL) — Jul 12, 2013
WELLTOWER INC. (WELL) (CIK 0000766704)
Date: July 12, 2013 · CIK: 0000766704 · Accession: 0000000000-13-038039
AI Filing Summary & Sentiment
Letter
July 12, 201 3 Via E -mail Mr. Scott A. Estes Chief Financial Officer Health Care REIT, Inc. 4500 Dorr Street Toledo , Ohio 43615
Re: Health Care REIT, Inc. Form 10-K for the fiscal year ended December 31, 2012 Filed February 26, 201 3 File No. 1-8923
Dear Mr. Estes :
We have reviewed your response letter filed on June 26, 2013 and have the following additional comment.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstanc es or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to our comment, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 2012
Item 1. Business
Investment Types, page 6
1. We note your response to prior comment 1. Please confirm that you will expand your disclosure within future filings to address some of the aspects of your response includ ing the indication that certain of the properties in your portfolio may sell at a discount to market price as a result of the rights held by certain purchase option holders. Additionally, please tell us the gain or loss on the sale of the 17 properties wh ich were disposed of pursuant to the terms of the purchase options in the original lease.
Mr. Scott A. Estes Health Care REIT, Inc. July 12, 201 3 Page 2
You may contact Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 -3629 if you have questions regarding comments on the financial statemen ts and related matters.
Sincerely,
/s/ Kevin Woody
Show Raw Text
July 12, 201 3
Via E -mail
Mr. Scott A. Estes
Chief Financial Officer
Health Care REIT, Inc.
4500 Dorr Street
Toledo , Ohio 43615
Re: Health Care REIT, Inc.
Form 10-K for the fiscal year ended December 31, 2012
Filed February 26, 201 3
File No. 1-8923
Dear Mr. Estes :
We have reviewed your response letter filed on June 26, 2013 and have the following
additional comment.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response. If you do not believe our comment appl ies to your facts and circumstanc es or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to our comment, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 2012
Item 1. Business
Investment Types, page 6
1. We note your response to prior comment 1. Please confirm that you will expand your
disclosure within future filings to address some of the aspects of your response includ ing
the indication that certain of the properties in your portfolio may sell at a discount to
market price as a result of the rights held by certain purchase option holders.
Additionally, please tell us the gain or loss on the sale of the 17 properties wh ich were
disposed of pursuant to the terms of the purchase options in the original lease.
Mr. Scott A. Estes
Health Care REIT, Inc.
July 12, 201 3
Page 2
You may contact Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 -3629 if
you have questions regarding comments on the financial statemen ts and related matters.
Sincerely,
/s/ Kevin Woody
Kevin Woody
Branch Chief