Correspondence 0001042776-23-000150 from Piedmont Realty Trust, Inc. (PDM)
Piedmont Realty Trust, Inc.
Date: Sept. 21, 2023 · CIK: 0001042776 · Accession: 0001042776-23-000150
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34626
Referenced dates: September 21, 2023
Letter
VIA EDGAR AND EMAIL Division of Corporation Finance Office of Real Estate and Construction Washington D.C. 20549 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 Ms. Breslin:
This letter is submitted in response to your letter dated September 21, 2023, regarding a comment by the Staff of the Securities and Exchange Commission (the “Commission”) related to the above referenced filing by Piedmont Office Realty Trust, Inc. (the “Company”). We welcome the opportunity to discuss our response with you and are available to do so at (770) 418-8800.
For your convenience, we have repeated the comment as shown in your letter prior to the response.
Form 10-K for Fiscal Year Ended December 31, 2022
Note 2. Summary of Significant Accounting Policies
Goodwill, page F-13
Comment:
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.
Response:
In future filings, we will include a description of the facts and circumstances leading to a goodwill impairment in accordance with ASC 350-20-50-2.
Sincerely,
/s/ Laura P. Moon
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CORRESP 1 filename1.htm Document PIEDMONT OFFICE REALTY TRUST, INC VIA EDGAR AND EMAIL September 21, 2023 Ms. Mary Beth Breslin Industry Office Chief Division of Corporation Finance Office of Real Estate and Construction U.S. Securities and Exchange Commission 100 F Street, NE Washington D.C. 20549 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 Ms. Breslin: This letter is submitted in response to your letter dated September 21, 2023, regarding a comment by the Staff of the Securities and Exchange Commission (the “Commission”) related to the above referenced filing by Piedmont Office Realty Trust, Inc. (the “Company”). We welcome the opportunity to discuss our response with you and are available to do so at (770) 418-8800. For your convenience, we have repeated the comment as shown in your letter prior to the response. Form 10-K for Fiscal Year Ended December 31, 2022 Note 2. Summary of Significant Accounting Policies Goodwill, page F-13 Comment: 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. Response: In future filings, we will include a description of the facts and circumstances leading to a goodwill impairment in accordance with ASC 350-20-50-2. Sincerely, /s/ Laura P. Moon Laura P. Moon Chief Accounting Officer Piedmont Office Realty Trust, Inc. CC: Mr. Paul Cline, Securities and Exchange Commission Mr. C. Brent Smith, President, Principal Executive Officer and Director Mr. Robert E. Bowers, Chief Financial Officer, Principal Financial Officer Mr. Mark Scalese, Deloitte & Touche LLP Mr. Keith Townsend, Esq., King & Spalding, LLP Mr. Zachary Cochran, Esq., King & Spalding, LLP