SEC Comment Letter for AGREE REALTY CORP (ADC, ADC-PA) (CIK 0000917251) (ADC) — Jul 7, 2011
AGREE REALTY CORP (ADC, ADC-PA) (CIK 0000917251)
Date: July 7, 2011 · CIK: 0000917251 · Accession: 0000000000-11-041250
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12928
Referenced dates: June 16, 2011, June 2, 2011
Letter
Re: Agree Realty Corporation Form 10-K Filed March 15, 2011 File No. 001-12928 Dear Mr. Maximiuk:
July 7, 2011 Via Fax
Mr. Alan Maximiuk Vice President, Chief Financ ial Officer and Secretary Agree Realty Corporation 31850 Northwestern Highway Farmington Hills, Michigan 48334
We have reviewed your response letter dated June 16, 2011 and have the following additional comments. In some of our comments, we may ask you to provide us with information so we may bette r understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2010
Development and Acquisition Summary, page 18 1. We note your response to comment 2 in our letter dated June 2, 2011. Please revise future periodic f ilings to disclose how you cal culate NOI for the purposes of arriving at your weighted average capit alization rate for your acquisitions and dispositions, in particular, the basi s for which you make any assumptions on future occupancy, rents or property expenses. Financial Statements
Alan Maximiuk Agree Realty Corporation July 7, 2011 Page
Consolidated Balance Sheets, page F-3
2. We have considered your response to our prior comment 6. We are unclear how you determined that none of the disclosu re requirements discussed in ASC Topic 805-10-50-2 (a) through (g) are relevant to the acquisition of single tenant properties. Additionally, pl ease tell us the total acqui sition cost of properties acquired during 2010 and provide us with a an alysis that reconciles the assets and liabilities recorded as part of th e acquisitions to the purchase price.
You may contact Robert Telewicz, St aff Accountant at (202)551-3438 or the undersigned at (202)551-3629 if you have ques tions regarding comments on the financial statements and related matters. Please cont act Adam Turk, Staff Attorney at (202)551- 3657 or Sonia Barros, Special Counsel at (202)551-3655 with a ny other questions. S i n c e r e l y , /s/ Kevin Woody Kevin Woody Accounting Branch Chief
Show Raw Text
July 7, 2011
Via Fax
Mr. Alan Maximiuk Vice President, Chief Financ ial Officer and Secretary
Agree Realty Corporation 31850 Northwestern Highway
Farmington Hills, Michigan 48334
Re: Agree Realty Corporation
Form 10-K Filed March 15, 2011 File No. 001-12928
Dear Mr. Maximiuk:
We have reviewed your response letter dated June 16, 2011 and have the
following additional comments. In some of our comments, we may ask you to provide us with information so we may bette r understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2010
Development and Acquisition Summary, page 18
1. We note your response to comment 2 in our letter dated June 2, 2011. Please
revise future periodic f ilings to disclose how you cal culate NOI for the purposes
of arriving at your weighted average capit alization rate for your acquisitions and
dispositions, in particular, the basi s for which you make any assumptions on
future occupancy, rents or property expenses.
Financial Statements
Alan Maximiuk
Agree Realty Corporation July 7, 2011 Page
2
Consolidated Balance Sheets, page F-3
2. We have considered your response to our prior comment 6. We are unclear how
you determined that none of the disclosu re requirements discussed in ASC Topic
805-10-50-2 (a) through (g) are relevant to the acquisition of single tenant
properties. Additionally, pl ease tell us the total acqui sition cost of properties
acquired during 2010 and provide us with a an alysis that reconciles the assets and
liabilities recorded as part of th e acquisitions to the purchase price.
You may contact Robert Telewicz, St aff Accountant at (202)551-3438 or the
undersigned at (202)551-3629 if you have ques tions regarding comments on the financial
statements and related matters. Please cont act Adam Turk, Staff Attorney at (202)551-
3657 or Sonia Barros, Special Counsel at (202)551-3655 with a ny other questions.
S i n c e r e l y ,
/s/ Kevin Woody Kevin Woody
Accounting Branch Chief