SEC Comment Letter for BRANDYWINE REALTY TRUST (BDN) (CIK 0000790816) (BDN) — Apr 9, 2012
BRANDYWINE REALTY TRUST (BDN) (CIK 0000790816)
Date: April 9, 2012 · CIK: 0000790816 · Accession: 0000000000-12-017951
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-24407, 001-09106
Referenced dates: March 29, 2012
Letter
April 9, 2012 VIA E-Mail Mr. Howard M. Sipzner Executive Vice President and Chief Financial Officer Brandywine Realty Trust 555 East Lancaster Avenue Radnor, Pennsylvania 19087
Re: Brandywine Realty Trust Form 10-K for the year ended December 31, 2011 Filed on February 24, 2012 File No. 001-09106 Brandywine Operating Partnership, L.P. Form 10-K for the year ended December 31, 2011 Filed on February 24, 2012 File No. 000-24407
Dear Mr. Howard M. Sipzner: We have reviewed your response letter dated March 29, 2012 and have the following comments. In our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, 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 THE YEAR ENDED DECEMBER 31, 2011
Depreciation and Amortization, page F-20
1. We have considered your response to comme nt three in your lett er dated March 29, 2012 and are unable to agree with your analysis. Please amend your December 31, 2011 10-K to restate your financial stat ements to properly reflect the out of period adjustment as a correction of an error. Reference is made to paragraph 250-10-45-22 to 24 of the FASB Accounting Standards Codification.
Mr. Howard M. Sipzner Brandywine Realty Trust Brandywine Operating Partnership, L.P. April 9, 2012 Page 2
2. Further to our above comment, please file an Item 4.02 8-K for the Form 10-K for the year ended December 31, 2011. The Form 8-K should include the date of the conclusion regarding non-reliance, the fina ncial statement years and peri ods that should no longer be relied upon, a brief description of the f acts underlying your conclusion, a statement whether your audit committee or its alternative has discus sed this matter with your independent accountants, and your time frame for filing the restated financial statements.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. 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. You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3629 if you have any questions.
Sincerely,
/s/ Kevin Woody
K e v i n W o o d y
B r a n c h C h i e f
Show Raw Text
April 9, 2012
VIA E-Mail
Mr. Howard M. Sipzner Executive Vice President and Chief Financial Officer Brandywine Realty Trust 555 East Lancaster Avenue Radnor, Pennsylvania 19087
Re: Brandywine Realty Trust
Form 10-K for the year ended December 31, 2011
Filed on February 24, 2012 File No. 001-09106 Brandywine Operating Partnership, L.P.
Form 10-K for the year ended December 31, 2011
Filed on February 24, 2012 File No. 000-24407
Dear Mr. Howard M. Sipzner:
We have reviewed your response letter dated March 29, 2012 and have the following
comments. In our comments, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, 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 THE YEAR ENDED DECEMBER 31, 2011
Depreciation and Amortization, page F-20
1. We have considered your response to comme nt three in your lett er dated March 29, 2012
and are unable to agree with your analysis. Please amend your December 31, 2011 10-K
to restate your financial stat ements to properly reflect the out of period adjustment as a
correction of an error. Reference is made to paragraph 250-10-45-22 to 24 of the FASB
Accounting Standards Codification.
Mr. Howard M. Sipzner
Brandywine Realty Trust Brandywine Operating Partnership, L.P. April 9, 2012 Page 2
2. Further to our above comment, please file an Item 4.02 8-K for the Form 10-K for the
year ended December 31, 2011. The Form 8-K should include the date of the conclusion
regarding non-reliance, the fina ncial statement years and peri ods that should no longer be
relied upon, a brief description of the f acts underlying your conclusion, a statement
whether your audit committee or its alternative has discus sed this matter with your
independent accountants, and your time frame for filing the restated financial statements.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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.
You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3629 if you have
any questions.
Sincerely,
/s/ Kevin Woody
K e v i n W o o d y
B r a n c h C h i e f