SEC Comment Letter for AGREE REALTY CORP (ADC, ADC-PA) (CIK 0000917251) (ADC) — Dec 19, 2016
AGREE REALTY CORP (ADC, ADC-PA) (CIK 0000917251)
Date: Dec. 19, 2016 · CIK: 0000917251 · Accession: 0000000000-16-105446
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12928
Letter
Mail Stop 3233 December 16, 2016 Via E -mail Matthew M. Partridge Chief Financial Officer Agree Realty Corporation 70 E. Long Lake Road Bloomfield Hills, Michigan 48304
Re: Agree Realty Corporation Form 10-K for Fiscal Year Ended December 31, 2015 Filed March 11, 2016 File No. 001-12928
Dear Mr. Partridge :
We have reviewed your filing an d have the following comment. Please respond to this comment within ten busine ss days by providing the requested information or advis e 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.
Properties, page 16
1. We note your press release dated October 24, 2016 discussing your development projects. In future Exchange Act periodic reports, please clarify the amount of property you hold for developmen t and disclose anticipated completion dates, costs incurred to date and budgeted costs. For completed developments, please disclose development and redevelopment expenditures per square foot and clarify whether you have included leasing costs. For materi al amounts of land, please discuss the amount of development the land could support.
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 abs ence of action by the staff.
Matthew M. Partridge Agree Realty Corporation December 16, 2016 Page 2
Please contact Rahul K. Patel, Staff Attorney , at (202) 551 -3799 or me at (202) 551 -3466 with any questions.
Sincerely,
/s/ Coy Garrison
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Mail Stop 3233 December 16, 2016 Via E -mail Matthew M. Partridge Chief Financial Officer Agree Realty Corporation 70 E. Long Lake Road Bloomfield Hills, Michigan 48304 Re: Agree Realty Corporation Form 10-K for Fiscal Year Ended December 31, 2015 Filed March 11, 2016 File No. 001-12928 Dear Mr. Partridge : We have reviewed your filing an d have the following comment. Please respond to this comment within ten busine ss days by providing the requested information or advis e 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. Properties, page 16 1. We note your press release dated October 24, 2016 discussing your development projects. In future Exchange Act periodic reports, please clarify the amount of property you hold for developmen t and disclose anticipated completion dates, costs incurred to date and budgeted costs. For completed developments, please disclose development and redevelopment expenditures per square foot and clarify whether you have included leasing costs. For materi al amounts of land, please discuss the amount of development the land could support. 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 abs ence of action by the staff. Matthew M. Partridge Agree Realty Corporation December 16, 2016 Page 2 Please contact Rahul K. Patel, Staff Attorney , at (202) 551 -3799 or me at (202) 551 -3466 with any questions. Sincerely, /s/ Coy Garrison Coy Garrison Special Counsel Office of Real Estate and Commodities