SEC Comment Letter 0000000000-24-006275 to SIMON PROPERTY GROUP INC /DE/ (SPG, SPG-PJ) (CIK 0001063761) (SPG)
SIMON PROPERTY GROUP INC /DE/ (SPG, SPG-PJ) (CIK 0001063761)
Date: May 31, 2024 · CIK: 0001063761 · Accession: 0000000000-24-006275
AI Filing Summary & Sentiment
File numbers found in text: 001-14469, 001-36110
Letter
United States securities and exchange commission logo May 31, 2024 Brian J. McDade Chief Financial Officer Simon Property Group, Inc. 225 West Washington Street Indianapolis, IN 46204 Re:Simon Property Group, Inc. Simon Property Group, L.P. Form 10-K for Fiscal Year Ended December 31, 2023 Filed February 22, 2024 File Nos. 001-14469 and 001-36110 Dear Brian J. McDade: We have reviewed your filing and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 1.We note, on page 98, you indicate that you review properties for impairment and total sales per square foot can impact this assessment. Further, we note on page 60 you disclose that you consider net operating income to be a key operating measure. Please tell us if management considers comparable property NOI and sales per square foot to be key operating measures. If so, please include this disclosure in future Exchange Act periodic reports and tell us how you intend to present it. With respect to sales per square foot please address, as appropriate, the impact inflation has had on this metric. 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 LastNameBrian J. McDade Comapany NameSimon Property Group, Inc. May 31, 2024 Page 2 FirstName LastName Brian J. McDade Simon Property Group, Inc. May 31, 2024 Page 2 Please contact Kellie Kim at 202-551-3129 or Isaac Esquivel at 202-551-3395 if you have questions regarding comments on the financial statements and related matters. Please contact Benjamin Holt at 202-551-6614 or Stacie Gorman at 202-551-3585 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Steven E. Fivel
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United States securities and exchange commission logo
May 31, 2024
Brian J. McDade
Chief Financial Officer
Simon Property Group, Inc.
225 West Washington Street
Indianapolis, IN 46204
Re:Simon Property Group, Inc.
Simon Property Group, L.P.
Form 10-K for Fiscal Year Ended December 31, 2023
Filed February 22, 2024
File Nos. 001-14469 and 001-36110
Dear Brian J. McDade:
We have reviewed your filing and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
59
1.We note, on page 98, you indicate that you review properties for impairment and total
sales per square foot can impact this assessment. Further, we note on page 60 you disclose
that you consider net operating income to be a key operating measure. Please tell us if
management considers comparable property NOI and sales per square foot to be key
operating measures. If so, please include this disclosure in future Exchange Act periodic
reports and tell us how you intend to present it. With respect to sales per square foot
please address, as appropriate, the impact inflation has had on this metric.
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 LastNameBrian J. McDade
Comapany NameSimon Property Group, Inc.
May 31, 2024 Page 2
FirstName LastName
Brian J. McDade
Simon Property Group, Inc.
May 31, 2024
Page 2
Please contact Kellie Kim at 202-551-3129 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Benjamin Holt at 202-551-6614 or Stacie Gorman at 202-551-3585 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Steven E. Fivel