SEC Comment Letter for GETTY REALTY (GTY) — Aug 16, 2017
GETTY REALTY CORP /MD/ (GTY) (CIK 0001052752)
Date: Aug. 16, 2017 · CIK: 0001052752 · Accession: 0000000000-17-028941
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13777
Letter
Mail Stop 3233 August 15, 2017 Via E -mail Danion Fielding Vice President, Chief Financial Officer and Treasurer Getty Realty Corp. Two Jericho Plaza, Suite 110 Jericho, New York 11753
Re: Getty Realty Corp. Form 10-K for the y ear ended December 31, 2016 Filed March 2, 2017 File No. 001-13777
Dear Mr. Fielding :
We have limited our review of your filing to the financial statements and related disclosures and 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Note 10 – Discontinued Operations and Assets Held for Sale, page 63
1. We note that your discontinued operations consist of properties that have been classified as held for sale since June 30, 2014. Please tell us what consideration you gave to ASC 205-20-45-1 when determining that these assets should still be classified as held for sale, given the extended length of time that they have been classified as such. In your response, include an assessment of the probability that a sale will be consummated.
Item 9B. Other Information, page 68
2. We note that you have provided summarized financial information for CF United LLC in a form consistent with Rule 1 -02(bb) of Regulation S -X. This information may be unaudited. However, you have labeled the data as audite d and referred to a third -party accounting firm. In future filings, please include an audit report and consent from the
Danion Fielding Getty Realty Corp. August 15, 2017 Page 2
third -party accounting firm, or do not label the summarized financial information as audited.
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.
You may contact William Demarest, Accountant at 202 -551-3432 or me at 202 -551-3429 with any questions.
Sincerely,
/s/ Kristi Marrone
Show Raw Text
Mail Stop 3233
August 15, 2017
Via E -mail
Danion Fielding
Vice President, Chief Financial Officer and Treasurer
Getty Realty Corp.
Two Jericho Plaza, Suite 110
Jericho, New York 11753
Re: Getty Realty Corp.
Form 10-K for the y ear ended December 31, 2016
Filed March 2, 2017
File No. 001-13777
Dear Mr. Fielding :
We have limited our review of your filing to the financial statements and related
disclosures and 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 these comments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Note 10 – Discontinued Operations and Assets Held for Sale, page 63
1. We note that your discontinued operations consist of properties that have been classified
as held for sale since June 30, 2014. Please tell us what consideration you gave to ASC
205-20-45-1 when determining that these assets should still be classified as held for sale,
given the extended length of time that they have been classified as such. In your
response, include an assessment of the probability that a sale will be consummated.
Item 9B. Other Information, page 68
2. We note that you have provided summarized financial information for CF United LLC in
a form consistent with Rule 1 -02(bb) of Regulation S -X. This information may be
unaudited. However, you have labeled the data as audite d and referred to a third -party
accounting firm. In future filings, please include an audit report and consent from the
Danion Fielding
Getty Realty Corp.
August 15, 2017
Page 2
third -party accounting firm, or do not label the summarized financial information as
audited.
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.
You may contact William Demarest, Accountant at 202 -551-3432 or me at 202 -551-3429
with any questions.
Sincerely,
/s/ Kristi Marrone
Kristi Marrone
Staff Accountant
Office of Real Estate
& Commodities