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SEC Comment Letter for BRANDYWINE REALTY TRUST (BDN) (CIK 0000790816) (BDN) — Aug 15, 2019

BRANDYWINE REALTY TRUST (BDN) (CIK 0000790816)
Date: Aug. 15, 2019 · CIK: 0000790816 · Accession: 0000000000-19-012509

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Reasoning

File numbers found in text: 001-09106

Date
August 15, 2019
Author
Thomas E. Wirth
Form
UPLOAD
Company
BRANDYWINE REALTY TRUST (BDN) (CIK 0000790816)

Letter

August 15, 2019 Thomas E. Wirth Chief Financial Officer BRANDYWINE REALTY TRUST 2929 Walnut Street Suite 1700 Philadelphia, PA 19104 Re:BRANDYWINE REALTY TRUST Form 10-K for the year ended December 31, 2018 Filed February 22, 2019 File No. 001-09106 Dear Mr. Wirth: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the year ended December 31, 2018 Financial Statements Note 3. Real Estate Investments, page F-29 1.With note your disclosure relating to your acquisition of complete ownership of the Austin Portfolio. Please tell us how you considered the requirements of Items 2.01 and 9.01)(a)- (b) of Form 8-K with respect to this acquisition. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Jorge Bonilla, Staff Accountant, at (202) 551-3414 or Daniel Gordon, Senior Assistant Chief Accountant, at (202) 551-3486 with any questions.

FirstName LastNameThomas E. Wirth Comapany NameBRANDYWINE REALTY TRUST August 15, 2019 Page 2 FirstName LastName Thomas E. Wirth BRANDYWINE REALTY TRUST August 15, 2019 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate and Commodities

Show Raw Text
August 15, 2019
Thomas E. Wirth
Chief Financial Officer
BRANDYWINE REALTY TRUST
2929 Walnut Street
Suite 1700
Philadelphia, PA 19104
Re:BRANDYWINE REALTY TRUST
Form 10-K for the year ended December 31, 2018
Filed February 22, 2019
File No. 001-09106
Dear Mr. Wirth:
            We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for the year ended December 31, 2018
Financial Statements
Note 3. Real Estate Investments, page F-29
1.With note your disclosure relating to your acquisition of complete ownership of the Austin
Portfolio.  Please tell us how you considered the requirements of Items 2.01 and 9.01)(a)-
(b) of Form 8-K with respect to this acquisition.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Jorge Bonilla, Staff Accountant, at (202) 551-3414 or Daniel Gordon,
Senior Assistant Chief Accountant, at (202) 551-3486 with any questions.

 FirstName LastNameThomas E. Wirth
 Comapany NameBRANDYWINE REALTY TRUST
 August 15, 2019 Page 2
 FirstName LastName
Thomas E. Wirth
BRANDYWINE REALTY TRUST
August 15, 2019
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities