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SEC Comment Letter 0000000000-25-003915 to AGREE REALTY CORP (ADC)

AGREE REALTY CORP
Date: April 14, 2025 · CIK: 0000917251 · Accession: 0000000000-25-003915

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File numbers found in text: 001-12928

Date
April 14, 2025
Author
April 14, 2025
Form
UPLOAD
Company
AGREE REALTY CORP

Letter

Re: Agree Realty Corp Form 10-K for the year ended December 31, 2024 Filed February 11, 2025 File No. 001-12928 Dear Peter Coughenour:

April 14, 2025

Peter Coughenour Chief Financial Officer Agree Realty Corp 32301 Woodward Avenue Royal Oak, MI 48073

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 a 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 for the year ended December 31, 2024 Note 2. Summary of Significant Accounting Policies Segment Reporting, page F-15

1. Please tell us how you determined that your disclosure is compliant with the requirements of ASC 280-10-50-20. Reference is also made to ASU 2023-07. 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.

Please contact William Demarest at 202-551-3432 or Kristina Marrone at 202-551- 3429 with any questions.

Sincerely,
April 14, 2025
Page 2
Division of Corporation Finance
Office of Real Estate & Construction

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 14, 2025

Peter Coughenour
Chief Financial Officer
Agree Realty Corp
32301 Woodward Avenue
Royal Oak, MI 48073

 Re: Agree Realty Corp
 Form 10-K for the year ended December 31, 2024
 Filed February 11, 2025
 File No. 001-12928
Dear Peter Coughenour:

 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 a
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 for the year ended December 31, 2024
Note 2. Summary of Significant Accounting Policies
Segment Reporting, page F-15

1. Please tell us how you determined that your disclosure is compliant with
the
 requirements of ASC 280-10-50-20. Reference is also made to ASU 2023-07.
 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.

 Please contact William Demarest at 202-551-3432 or Kristina Marrone at
202-551-
3429 with any questions.

 Sincerely,
 April 14, 2025
Page 2

 Division of Corporation Finance
 Office of Real Estate & Construction
</TEXT>
</DOCUMENT>