SEC Comment Letter 0000000000-23-007495 to SITE Centers Corp. (SITC, SITC-PA) (CIK 0000894315) (SITC)
SITE Centers Corp. (SITC, SITC-PA) (CIK 0000894315)
Date: July 13, 2023 · CIK: 0000894315 · Accession: 0000000000-23-007495
AI Filing Summary & Sentiment
File numbers found in text: 001-11690
Letter
United States securities and exchange commission logo July 13, 2023 Conor Fennerty Chief Financial Officer SITE Centers Corp. 3300 Enterprise Parkway Beachwood, OH 44122 Re:SITE Centers Corp. Form 10-K for the Year Ended December 31, 2022 Filed February 23, 2023 Form 8-K filed April 25, 2023 File No. 001-11690 Dear Conor Fennerty: 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 our 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 our comment, we may have additional comments. Form 8-K filed April 25, 2023 Exhibit 99.1 Quarterly Financial Supplement Dated as of March 31, 2023 Site Centers Corp. Same Store Metrics, page 11 1.We note the reconciliation of SSNOI at both 100% and SITE Share on page 11 of your Quarterly Financial Supplement. It appears your presentation both: •Combines consolidated results with 100% of the operating results of your unconsolidated joint ventures and; •Reflects your share of unconsolidated joint ventures as though they are consolidated on a proportionate share basis. Please tell us how you determined this presentation is consistent with Question 100.04 of the Division's Compliance and Disclosure Interpretations for Non-GAAP Financial Measures.
FirstName LastNameConor Fennerty Comapany NameSITE Centers Corp. July 13, 2023 Page 2 FirstName LastName Conor Fennerty SITE Centers Corp. July 13, 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 Howard Efron at 202-551-3439 or Robert Telewicz at 202-551- 3438 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
United States securities and exchange commission logo
July 13, 2023
Conor Fennerty
Chief Financial Officer
SITE Centers Corp.
3300 Enterprise Parkway
Beachwood, OH 44122
Re:SITE Centers Corp.
Form 10-K for the Year Ended December 31, 2022
Filed February 23, 2023
Form 8-K filed April 25, 2023
File No. 001-11690
Dear Conor Fennerty:
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 our 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 our comment, we may have additional comments.
Form 8-K filed April 25, 2023
Exhibit 99.1 Quarterly Financial Supplement Dated as of March 31, 2023
Site Centers Corp. Same Store Metrics, page 11
1.We note the reconciliation of SSNOI at both 100% and SITE Share on page 11 of your
Quarterly Financial Supplement. It appears your presentation both:
•Combines consolidated results with 100% of the operating results of your
unconsolidated joint ventures and;
•Reflects your share of unconsolidated joint ventures as though they are consolidated
on a proportionate share basis.
Please tell us how you determined this presentation is consistent with Question 100.04 of
the Division's Compliance and Disclosure Interpretations for Non-GAAP Financial
Measures.
FirstName LastNameConor Fennerty
Comapany NameSITE Centers Corp.
July 13, 2023 Page 2
FirstName LastName
Conor Fennerty
SITE Centers Corp.
July 13, 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 Howard Efron at 202-551-3439 or Robert Telewicz at 202-551-
3438 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction