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SEC Comment Letter for G REIT INC (CIK 0001164246) — Jun 16, 2005

G REIT INC (CIK 0001164246)
Date: June 16, 2005 · CIK: 0001164246 · Accession: 0000000000-05-030378

AI Filing Summary & Sentiment

File numbers found in text: 000-50261

Date
June 16, 2005
Author
Steven Jacobs
Form
UPLOAD
Company
G REIT INC (CIK 0001164246)

Letter

Mail Stop 4561 VIA U.S. MAIL AND FAX (714) 667-6860 Mr. Scott D. Peters Chief Financial Officer G REIT, Inc. 1551 N. Tustin Avenue, Suite 200 Santa Ana, CA 92705

Re: G REIT, Inc. Form 10-K for the year ended December 31, 2004 Filed March 31, 2005 File No. 000-50261

Dear Mr. Peters:

We have reviewed your filing and have the following comments. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. In our comments, we ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the year ended December 31, 2004

Financial Statements and Notes

Note 7, Mortgage Loans Payable, page 84

1. Please tell us the factors you considered in determining, and disclose in future filings, whether your designated cash flow hedges qualify for hedge accounting under SFAS 133. If you qualify for hedge accounting under SFAS 133, tell us how you considered paragraph 30 of SFAS 133 in accounting for the changes in fair value. In your response, please also advise us of the accounting for the cash flow hedges disclosed in Notes 2 and 6 in the financial statements of Congress Center Property. * * * *

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an informed decision. 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 connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the disclosure in the filings;

* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filings or in response to our comments on your filings.

You may contact Josh Forgione, at (202) 551-3431, or me, at (202) 551-3403, if you have questions. Please respond to the comments included in this letter within ten business days or tell us when you will provide us with a response. Please file your response on EDGAR.

Sincerely,
Steven Jacobs
Accounting Branch Chief

Show Raw Text
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<TEXT>

      June 16, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX (714) 667-6860

Mr. Scott D. Peters
Chief Financial Officer
G REIT, Inc.
1551 N. Tustin Avenue, Suite 200
Santa Ana, CA  92705

      Re:	G REIT, Inc.
      Form 10-K for the year ended December 31, 2004
      Filed March 31, 2005
      File No. 000-50261

Dear Mr. Peters:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  In our comments, we ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2004

Financial Statements and Notes

Note 7, Mortgage Loans Payable, page 84

1. Please tell us the factors you considered in determining, and
disclose in future filings, whether your designated cash flow
hedges
qualify for hedge accounting under SFAS 133.   If you qualify for
hedge accounting under SFAS 133, tell us how you considered
paragraph
30 of SFAS 133 in accounting for the changes in fair value.  In
your
response, please also advise us of the accounting for the cash
flow
hedges disclosed in Notes 2 and 6 in the financial statements of
Congress Center Property.
*  *  *  *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

	You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within ten business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief

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Mr. Scott D. Peters
G REIT, Inc.
June 16, 2005
Page 1

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</DOCUMENT>