SEC Comment Letter for Piedmont Realty Trust, Inc. (PDM) (CIK 0001042776) (PDM) — Mar 31, 2014
Piedmont Realty Trust, Inc. (PDM) (CIK 0001042776)
Date: March 31, 2014 · CIK: 0001042776 · Accession: 0000000000-14-015952
AI Filing Summary & Sentiment
Reasoning
Letter
March 31, 2014 Via E -mail Mr. Robert E. Bowers Chief Financial Officer and Executive Vice -President Piedmont Office Realty Trust, Inc. 11695 Johns Creek Parkway, Ste. 350 Johns Creek, GA 30097
Re: Piedmont Office Realty Trust, Inc. Form 10-K for the year ended December 31, 2013 Filed February 18, 2014 File No. 1 -34626
Dear Mr. Bowers :
We have reviewed your filing an d have the following comments. In some of our comments, 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 provide the requested response. If you do not believe our comments apply 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 respo nse to these comments, we may have additional comments.
Form 10 -K for the year ended December 31, 2013
Liquidity and Capital Resources, page 29
1. We note your disclosure related to upcoming capital expenditures for the coming months. In future filings please include additional analysis of your capital expenditures that have occurred by breaking down total capital expenditures between new development, redevelopment/renovations and other capital expenditures by year. The total of these expenditures should reconcile to the cash flow statement. In addition please provide a narrative discussion for fluctuations from year to year and expectations for the future.
2. In addition, if you capitalize a significant amount of soft costs such as interes t, payroll and other G&A expenses please disclose the amount of these soft costs capitalized below the table that breaks down total capital expenditures between new development,
Mr. Robert E. Bowers Piedmont Office Real ty Trust, Inc. March 31, 2014 Page 2
redevelopment and other capital expenditures. Please provide a narrative disc ussion for fluctuations from year to year.
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 responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, pl ease 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 Isaac Esquivel, Staff Accountant at (202) 551 -3395 or me at (202) 551 - 3486 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Daniel L. Gordon
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March 31, 2014 Via E -mail Mr. Robert E. Bowers Chief Financial Officer and Executive Vice -President Piedmont Office Realty Trust, Inc. 11695 Johns Creek Parkway, Ste. 350 Johns Creek, GA 30097 Re: Piedmont Office Realty Trust, Inc. Form 10-K for the year ended December 31, 2013 Filed February 18, 2014 File No. 1 -34626 Dear Mr. Bowers : We have reviewed your filing an d have the following comments. In some of our comments, 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 provide the requested response. If you do not believe our comments apply 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 respo nse to these comments, we may have additional comments. Form 10 -K for the year ended December 31, 2013 Liquidity and Capital Resources, page 29 1. We note your disclosure related to upcoming capital expenditures for the coming months. In future filings please include additional analysis of your capital expenditures that have occurred by breaking down total capital expenditures between new development, redevelopment/renovations and other capital expenditures by year. The total of these expenditures should reconcile to the cash flow statement. In addition please provide a narrative discussion for fluctuations from year to year and expectations for the future. 2. In addition, if you capitalize a significant amount of soft costs such as interes t, payroll and other G&A expenses please disclose the amount of these soft costs capitalized below the table that breaks down total capital expenditures between new development, Mr. Robert E. Bowers Piedmont Office Real ty Trust, Inc. March 31, 2014 Page 2 redevelopment and other capital expenditures. Please provide a narrative disc ussion for fluctuations from year to year. 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 responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, pl ease 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 Isaac Esquivel, Staff Accountant at (202) 551 -3395 or me at (202) 551 - 3486 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Daniel L. Gordon Daniel L. Gordon Branch Chief