SEC Comment Letter for Piedmont Realty Trust, Inc. (PDM) (CIK 0001042776) (PDM) — Mar 10, 2011
Piedmont Realty Trust, Inc. (PDM) (CIK 0001042776)
Date: March 10, 2011 · CIK: 0001042776 · Accession: 0000000000-11-014985
AI Filing Summary & Sentiment
Letter
March 10, 2011
Mr. Donald A. Miller President Piedmont Office Realty Trust, Inc. 11695 Johns Creek Parkway , Suite 350 Johns Creek, GA 30097 Re: Piedmont Office R ealty Trust, Inc. Form 10- K Filed February 24, 2011 File N o. 001 -34626 Dear Mr. Miller : We have reviewed your filing 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will pr ovide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to th is comment , we may have additional comments.
Note 6. Notes Receivable, page F -17 1. Please clarify to us why you believe the notes receivable related to your investment in the 500 W. Monroe Building do not meet the criteria for impairment in ASC 310- 10-35. In your response , please explain 1) how you were able to extend the Mortgage Loan and first priority mezzanine loan given that you are not the holder of these loans, 2) whether or not you also extended the maturities of the mezzanine loans held by Pi edmont and 3) how you determined that it is probable that you w ill collect all principal amounts due on your mezzanine investments . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are r esponsible for the accuracy and adequacy of t he disclosures they have made.
Mr. Donald A. Miller Piedmont Office Realty Trust, Inc. March 10, 2011 Page 2
In responding to our comment , please provide a written statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Kristi Marrone at (202) 551- 3429 or me at (202) 551 -3486 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Daniel L. Gordon
Branch Chief
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March 10, 2011 Mr. Donald A. Miller President Piedmont Office Realty Trust, Inc. 11695 Johns Creek Parkway , Suite 350 Johns Creek, GA 30097 Re: Piedmont Office R ealty Trust, Inc. Form 10- K Filed February 24, 2011 File N o. 001 -34626 Dear Mr. Miller : We have reviewed your filing 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will pr ovide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to th is comment , we may have additional comments. Note 6. Notes Receivable, page F -17 1. Please clarify to us why you believe the notes receivable related to your investment in the 500 W. Monroe Building do not meet the criteria for impairment in ASC 310- 10-35. In your response , please explain 1) how you were able to extend the Mortgage Loan and first priority mezzanine loan given that you are not the holder of these loans, 2) whether or not you also extended the maturities of the mezzanine loans held by Pi edmont and 3) how you determined that it is probable that you w ill collect all principal amounts due on your mezzanine investments . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are r esponsible for the accuracy and adequacy of t he disclosures they have made. Mr. Donald A. Miller Piedmont Office Realty Trust, Inc. March 10, 2011 Page 2 In responding to our comment , please provide a written statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclosure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Kristi Marrone at (202) 551- 3429 or me at (202) 551 -3486 if you have questions regarding comments on the financial statements and related matters. Sincerely, Daniel L. Gordon Branch Chief