SEC Comment Letter 0000000000-23-010411 to Piedmont Realty Trust, Inc. (PDM)
Piedmont Realty Trust, Inc.
Date: Sept. 21, 2023 · CIK: 0001042776 · Accession: 0000000000-23-010411
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34626
Letter
United States securities and exchange commission logo September 21, 2023 Laura Moon Chief Accounting Officer Piedmont Office Realty Trust, Inc. 5565 Glenridge Connector, Ste. 450 Atlanta, GA 30342 Re:Piedmont Office Realty Trust, Inc. Form 10-K for the year ended December 31, 2022 Filed February 23, 2023 File No. 001-34626 Dear Laura Moon: 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 10-K for the year ended December 31, 2022 Note 2. Summary of Significant Accounting Policies Goodwill, page F-13 1.We note that you recognized a $16 million goodwill impairment attributable to the Washington, D.C./Northern Virginia reporting unit. Please expand your disclosure in future filings to include a description of the facts and circumstances leading to the impairment in accordance with ASC 350-20-50-2. We note the explanation on page 36 that the impairment loss was due to the decline of the stock market and your stock price, but it is unclear how that factor solely impacted the Washington, D.C./Northern Virginia reporting unit. 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 LastNameLaura Moon Comapany NamePiedmont Office Realty Trust, Inc. September 21, 2023 Page 2 FirstName LastName Laura Moon Piedmont Office Realty Trust, Inc. September 21, 2023 Page 2 You may contact Paul Cline at 202-551-3851 or Kristi Marrone at 202-551-3429 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
September 21, 2023
Laura Moon
Chief Accounting Officer
Piedmont Office Realty Trust, Inc.
5565 Glenridge Connector, Ste. 450
Atlanta, GA 30342
Re:Piedmont Office Realty Trust, Inc.
Form 10-K for the year ended December 31, 2022
Filed February 23, 2023
File No. 001-34626
Dear Laura Moon:
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 10-K for the year ended December 31, 2022
Note 2. Summary of Significant Accounting Policies
Goodwill, page F-13
1.We note that you recognized a $16 million goodwill impairment attributable to the
Washington, D.C./Northern Virginia reporting unit. Please expand your disclosure in
future filings to include a description of the facts and circumstances leading to the
impairment in accordance with ASC 350-20-50-2. We note the explanation on page 36
that the impairment loss was due to the decline of the stock market and your stock price,
but it is unclear how that factor solely impacted the Washington, D.C./Northern Virginia
reporting unit.
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 LastNameLaura Moon
Comapany NamePiedmont Office Realty Trust, Inc.
September 21, 2023 Page 2
FirstName LastName
Laura Moon
Piedmont Office Realty Trust, Inc.
September 21, 2023
Page 2
You may contact Paul Cline at 202-551-3851 or Kristi Marrone at 202-551-3429 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction