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UPLOAD Filing

AGREE REALTY CORP
Date: June 16, 2025 · CIK: 0000917251 · Accession: 0000000000-25-006292

Financial Reporting Regulatory Compliance Internal Controls

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File numbers found in text: 001-12928

Date
June 16, 2025
Author
Division of Corporation Finance
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:

June 16, 2025

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

We have reviewed your June 2, 2025 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our April 14, 2025 letter.

Form 10-K for the year ended December 31, 2024 Note 2. Summary of Significant Accounting Policies Segment Reporting, page F-15

1. We note your response to our prior comment. Please clarify whether significant segment expenses and other segment items are identical to what is presented on the face of your Consolidated Statements of Operations and Comprehensive Income. If so, include disclosure to this effect in future filings. Please contact William Demarest at 202-551-3432 or Kristina Marrone at 202-551- 3429 if you have questions regarding comments on the financial statements and related matters. June 16, 2025 Page 2

Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 June 16, 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 reviewed your June 2, 2025 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our April 14,
2025 letter.

Form 10-K for the year ended December 31, 2024
Note 2. Summary of Significant Accounting Policies
Segment Reporting, page F-15

1. We note your response to our prior comment. Please clarify whether
significant
 segment expenses and other segment items are identical to what is
presented on the
 face of your Consolidated Statements of Operations and Comprehensive
Income. If
 so, include disclosure to this effect in future filings.
 Please contact William Demarest at 202-551-3432 or Kristina Marrone at
202-551-
3429 if you have questions regarding comments on the financial statements and
related
matters.
 June 16, 2025
Page 2

 Sincerely,

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