SEC Comment Letter 0000000000-23-012466 to REDWOOD TRUST INC (RWT)
REDWOOD TRUST INC
Date: Nov. 14, 2023 · CIK: 0000930236 · Accession: 0000000000-23-012466
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13759
Letter
United States securities and exchange commission logo November 14, 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 Form 8-K filed October 30, 2023 Response dated October 11, 2023 File No. 001-13759 Dear Brooke E. Carillo: We have reviewed your October 11, 2023 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 September 27, 2023 letter. Form 8-K filed October 30, 2023 Exhibit 99.1 Non-GAAP Disclosures, page 10 1.We have considered your response to comment 1 and your revised disclosure related to non-GAAP Earnings Available for Distribution within your most recent earnings release. Your adjustment for Change in economic basis of investments presents income from your investments on an alternative basis. This adjustment is inconsistent with Question 100.04 of the Compliance & Disclosure Interpretations on the use of Non-GAAP Financial Measures. Specifically, changing the income recognition appears to be an individually tailored measurement principle. Please revise your non-GAAP measure to eliminate the adjustment for Change in economic basis of investments.
FirstName LastNameBrooke E. Carillo Comapany NameRedwood Trust, Inc. November 14, 2023 Page 2 FirstName LastName Brooke E. Carillo Redwood Trust, Inc. November 14, 2023 Page 2 Please contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
November 14, 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
Form 8-K filed October 30, 2023
Response dated October 11, 2023
File No. 001-13759
Dear Brooke E. Carillo:
We have reviewed your October 11, 2023 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 September 27, 2023
letter.
Form 8-K filed October 30, 2023
Exhibit 99.1
Non-GAAP Disclosures, page 10
1.We have considered your response to comment 1 and your revised disclosure related to
non-GAAP Earnings Available for Distribution within your most recent earnings release.
Your adjustment for Change in economic basis of investments presents income from your
investments on an alternative basis. This adjustment is inconsistent with Question 100.04
of the Compliance & Disclosure Interpretations on the use of Non-GAAP Financial
Measures. Specifically, changing the income recognition appears to be an individually
tailored measurement principle. Please revise your non-GAAP measure to eliminate the
adjustment for Change in economic basis of investments.
FirstName LastNameBrooke E. Carillo
Comapany NameRedwood Trust, Inc.
November 14, 2023 Page 2
FirstName LastName
Brooke E. Carillo
Redwood Trust, Inc.
November 14, 2023
Page 2
Please contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction