SEC Comment Letter 0000000000-24-008127 to DYNEX CAPITAL INC (DX, DX-PC) (CIK 0000826675) (DX)
DYNEX CAPITAL INC (DX, DX-PC) (CIK 0000826675)
Date: July 17, 2024 · CIK: 0000826675 · Accession: 0000000000-24-008127
AI Filing Summary & Sentiment
File numbers found in text: 001-09819
Letter
July 17, 2024 Robert S. Colligan Executive Vice President, Chief Financial Officer and Secretary Dynex Capital, Inc. 4991 Lake Brook Drive, Suite 100 Glen Allen, VA 23060 Re:Dynex Capital, Inc. Form 10-K for the year ended December 31, 2023 Form 8-K filed April 22, 2024 File No. 001-09819 Dear Robert S. Colligan: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K filed April 22, 2024 Exhibit 99.1 Non-GAAP Financial Measures, page 7 1.We note your reconciliation of Adjusted net interest spread. Please expand your disclosure in future filings to describe why you believe this measure provides useful information to investors. Additionally, please tell us how the adjustment Impact from TBA dollar roll transactions is calculated and how it relates to your estimated TBA net interest spread. In closing, 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. Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468 with any questions.
July 17, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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July 17, 2024
Robert S. Colligan
Executive Vice President, Chief Financial Officer and Secretary
Dynex Capital, Inc.
4991 Lake Brook Drive, Suite 100
Glen Allen, VA 23060
Re:Dynex Capital, Inc.
Form 10-K for the year ended December 31, 2023
Form 8-K filed April 22, 2024
File No. 001-09819
Dear Robert S. Colligan:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 8-K filed April 22, 2024
Exhibit 99.1
Non-GAAP Financial Measures, page 7
1.We note your reconciliation of Adjusted net interest spread. Please expand your
disclosure in future filings to describe why you believe this measure provides useful
information to investors. Additionally, please tell us how the adjustment Impact from
TBA dollar roll transactions is calculated and how it relates to your estimated TBA net
interest spread.
In closing, 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.
Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468 with any
questions.
July 17, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction