SEC Comment Letter 0000000000-23-005763 to COPT DEFENSE PROPERTIES (CDP) (CIK 0000860546) (CDP)
COPT DEFENSE PROPERTIES (CDP) (CIK 0000860546)
Date: June 1, 2023 · CIK: 0000860546 · Accession: 0000000000-23-005763
AI Filing Summary & Sentiment
File numbers found in text: 001-14023
Letter
United States securities and exchange commission logo June 1, 2023 Anthony Mifsud Chief Financial Officer Corporate Office Properties Trust 6711 Columbia Gateway Drive, Suite 300 Columbia, MD 21046 Re:Corporate Office Properties Trust Form 10-K for fiscal year ended December 31, 2022 Filed February 24, 2023 File No. 001-14023 Dear Anthony Mifsud: We have limited our review of your filing to the financial statements and related disclosures 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 fiscal year ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Funds from Operations, page 34 1.We note your presentation of Diluted FFO per share and Diluted FFO per share, as adjusted for comparability for which you note Diluted EPS is the most directly comparable GAAP measure. However given the impact of discontinued operations for the periods presented, it is unclear whether these non-GAAP financial measures contemplate discontinued operations. Therefore in future periodic filings, please present with equal or greater prominence the most directly comparable measure calculated in accordance with GAAP for these non-GAAP financial measures. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the Division's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameAnthony Mifsud Comapany NameCorporate Office Properties Trust June 1, 2023 Page 2 FirstName LastName Anthony Mifsud Corporate Office Properties Trust June 1, 2023 Page 2 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. You may contact Mark Rakip, Staff Accountant at 202.551.3573 or Isaac Esquivel, Staff Accountant at 202.551.3395 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
June 1, 2023
Anthony Mifsud
Chief Financial Officer
Corporate Office Properties Trust
6711 Columbia Gateway Drive, Suite 300
Columbia, MD 21046
Re:Corporate Office Properties Trust
Form 10-K for fiscal year ended December 31, 2022
Filed February 24, 2023
File No. 001-14023
Dear Anthony Mifsud:
We have limited our review of your filing to the financial statements and related
disclosures 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 fiscal year ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Funds from Operations, page 34
1.We note your presentation of Diluted FFO per share and Diluted FFO per share, as
adjusted for comparability for which you note Diluted EPS is the most directly
comparable GAAP measure. However given the impact of discontinued operations for the
periods presented, it is unclear whether these non-GAAP financial measures contemplate
discontinued operations. Therefore in future periodic filings, please present with equal or
greater prominence the most directly comparable measure calculated in accordance with
GAAP for these non-GAAP financial measures. Refer to Item 10(e)(1)(i)(A) of
Regulation S-K and Question 102.10(a) of the Division's Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures.
FirstName LastNameAnthony Mifsud
Comapany NameCorporate Office Properties Trust
June 1, 2023 Page 2
FirstName LastName
Anthony Mifsud
Corporate Office Properties Trust
June 1, 2023
Page 2
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.
You may contact Mark Rakip, Staff Accountant at 202.551.3573 or Isaac Esquivel, Staff
Accountant at 202.551.3395 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction