SEC Comment Letter 0000000000-23-009620 to REDWOOD TRUST INC (RWT)
REDWOOD TRUST INC
Date: Aug. 31, 2023 · CIK: 0000930236 · Accession: 0000000000-23-009620
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13759
Letter
United States securities and exchange commission logo August 31, 2023 Brooke E. Carillo Chief Financial Officer Redwood Trust, Inc. One Belvedere Place, Suite 300 Mill Valley, CA 94941 Re:Redwood Trust, Inc. Form 10-K for the year ended December 31, 2022 Filed March 1, 2023 Form 8-K filed July 27, 2023 File No. 001-13759 Dear Brooke E. Carillo: We have limited our review of your filing to the financial statements and related disclosures 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 business days by providing the requested information or advise 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. Form 8-K filed July 27, 2023 Exhibit 99.1 Non-GAAP Disclosures, page 10 1.We note your reconciliation of GAAP Net Income Available to Common Stockholders to non-GAAP Earnings Available for Distribution; specifically, we note your reconciling item for change in economic basis of investments and your note (4) to the table. Please further clarify for us how you derive estimated economic income. In addition, please tell us how you determined it was appropriate to adjust for this item. 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.
FirstName LastNameBrooke E. Carillo Comapany NameRedwood Trust, Inc. August 31, 2023 Page 2 FirstName LastName Brooke E. Carillo Redwood Trust, Inc. August 31, 2023 Page 2 You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
August 31, 2023
Brooke E. Carillo
Chief Financial Officer
Redwood Trust, Inc.
One Belvedere Place, Suite 300
Mill Valley, CA 94941
Re:Redwood Trust, Inc.
Form 10-K for the year ended December 31, 2022
Filed March 1, 2023
Form 8-K filed July 27, 2023
File No. 001-13759
Dear Brooke E. Carillo:
We have limited our review of your filing to the financial statements and related
disclosures 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 business days by providing the requested
information or advise 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.
Form 8-K filed July 27, 2023
Exhibit 99.1
Non-GAAP Disclosures, page 10
1.We note your reconciliation of GAAP Net Income Available to Common Stockholders to
non-GAAP Earnings Available for Distribution; specifically, we note your reconciling
item for change in economic basis of investments and your note (4) to the table. Please
further clarify for us how you derive estimated economic income. In addition, please tell
us how you determined it was appropriate to adjust for this item.
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.
FirstName LastNameBrooke E. Carillo
Comapany NameRedwood Trust, Inc.
August 31, 2023 Page 2
FirstName LastName
Brooke E. Carillo
Redwood Trust, Inc.
August 31, 2023
Page 2
You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction