SEC Comment Letter 0000000000-24-003867 to COPT DEFENSE PROPERTIES (CDP) (CIK 0000860546) (CDP)
COPT DEFENSE PROPERTIES (CDP) (CIK 0000860546)
Date: April 10, 2024 · CIK: 0000860546 · Accession: 0000000000-24-003867
AI Filing Summary & Sentiment
File numbers found in text: 001-14023
Letter
United States securities and exchange commission logo April 10, 2024 Anthony Mifsud Executive Vice President and Chief Financial Officer COPT Defense Properties 6711 Columbia Gateway Drive, Suite 300 Columbia, Maryland 21046 Re:COPT Defense Properties Form 10-K for the fiscal year ended December 31, 2023 Filed February 22, 2024 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. 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 our 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 10-K filed February 22, 2024 Notes to consolidated financial statements 8. Debt, net Unsecured senior notes, page F-30 1.We note you issued $345.0 million Exchangeable Senior Notes at 5.25% due in September 2028 (the “Notes”). Please tell us your accounting policy for the Notes and provide us your analysis that supports your chosen accounting treatment. Your response should highlight the significant terms of the Notes, your consideration of the guidance in ASC 815-15 and 40, and any other citations to authoritative GAAP literature that provide support. 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.
FirstName LastNameAnthony Mifsud Comapany NameCOPT Defense Properties April 10, 2024 Page 2 FirstName LastName Anthony Mifsud COPT Defense Properties April 10, 2024 Page 2 Please contact Peter McPhun at 202-551-3581 or Wilson Lee at 202-551-3468 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
United States securities and exchange commission logo
April 10, 2024
Anthony Mifsud
Executive Vice President and Chief Financial Officer
COPT Defense Properties
6711 Columbia Gateway Drive, Suite 300
Columbia, Maryland 21046
Re:COPT Defense Properties
Form 10-K for the fiscal year ended December 31, 2023
Filed February 22, 2024
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.
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
our 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 10-K filed February 22, 2024
Notes to consolidated financial statements
8. Debt, net
Unsecured senior notes, page F-30
1.We note you issued $345.0 million Exchangeable Senior Notes at 5.25% due in
September 2028 (the “Notes”). Please tell us your accounting policy for the Notes and
provide us your analysis that supports your chosen accounting treatment. Your response
should highlight the significant terms of the Notes, your consideration of the guidance in
ASC 815-15 and 40, and any other citations to authoritative GAAP literature that
provide support.
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.
FirstName LastNameAnthony Mifsud
Comapany NameCOPT Defense Properties
April 10, 2024 Page 2
FirstName LastName
Anthony Mifsud
COPT Defense Properties
April 10, 2024
Page 2
Please contact Peter McPhun at 202-551-3581 or Wilson Lee at 202-551-3468 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction