SEC Comment Letter for REDWOOD TRUST INC (RWT, RWTN, RWTO, RWTP, RWTQ, RWT-PA) (CIK 0000930236) (RWT) — Aug 14, 2015
REDWOOD TRUST INC (RWT, RWTN, RWTO, RWTP, RWTQ, RWT-PA) (CIK 0000930236)
Date: Aug. 14, 2015 · CIK: 0000930236 · Accession: 0000000000-15-041699
AI Filing Summary & Sentiment
Reasoning
Letter
August 14, 2015 Via E -Mail Christopher J. Abate Chief Financial Officer Redwood Trust, Inc. One Belvedere Place, Suite 300 Mill Valley , CA 94941
Re: Redwood Trust, Inc. Form 10 -K for the Fiscal Ye ar Ended December 31, 20 14 Filed February 25, 201 5 File No. 001 -13759
Dear Mr. Abate :
We have reviewed your July 22, 2015 response to our comment letter 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 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. Unless we note otherwise, our references to prior comments are to comments in our June 24 , 2015 letter .
Form 10 -K for the fiscal year ended December 31, 2014
Item 8. Financial Statements and Supplementary Data
Note 5. Fair Value of Financial Instruments, F -29
1. We note in your response to comment 2 that the difference in fair value estimates implied by pricing inputs obtained from market securitization activity versus from market whole loan transaction activity was minimal. Please clarify whether fair value estimates for your residential loans held -for-investment are based upon pricing inputs for both t he securitization market and the whole loan market and if so, confirm that differences between fair value estimates based upon the two markets are minimal as it relates specifically to residential loans held -for-
Christopher J. Abate Redwood Trust , Inc. August 14, 2015 Page 2
investment. Also, explain to us why you adj ust the above pricing inputs and the nature of the adjustments.
If you have any questions, you may contact Jorge L. Bonilla at (202) 551 -3414 or me at (202) 551 -3446 .
Sincerely,
/s/ Jaime G. John
Show Raw Text
August 14, 2015
Via E -Mail
Christopher J. Abate
Chief Financial Officer
Redwood Trust, Inc.
One Belvedere Place, Suite 300
Mill Valley , CA 94941
Re: Redwood Trust, Inc.
Form 10 -K for the Fiscal Ye ar Ended December 31, 20 14
Filed February 25, 201 5
File No. 001 -13759
Dear Mr. Abate :
We have reviewed your July 22, 2015 response to our comment letter 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 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. Unless we note otherwise, our references to prior comments are to comments
in our June 24 , 2015 letter .
Form 10 -K for the fiscal year ended December 31, 2014
Item 8. Financial Statements and Supplementary Data
Note 5. Fair Value of Financial Instruments, F -29
1. We note in your response to comment 2 that the difference in fair value estimates
implied by pricing inputs obtained from market securitization activity versus from
market whole loan transaction activity was minimal. Please clarify whether fair
value estimates for your residential loans held -for-investment are based upon
pricing inputs for both t he securitization market and the whole loan market and if
so, confirm that differences between fair value estimates based upon the two
markets are minimal as it relates specifically to residential loans held -for-
Christopher J. Abate
Redwood Trust , Inc.
August 14, 2015
Page 2
investment. Also, explain to us why you adj ust the above pricing inputs and the
nature of the adjustments.
If you have any questions, you may contact Jorge L. Bonilla at (202) 551 -3414 or
me at (202) 551 -3446 .
Sincerely,
/s/ Jaime G. John
Jaime G. John
Branch Chief