SEC Comment Letter for Whitestone REIT (WSR) (CIK 0001175535) (WSR) — Nov 9, 2017
Whitestone REIT (WSR) (CIK 0001175535)
Date: Nov. 9, 2017 · CIK: 0001175535 · Accession: 0000000000-17-039849
AI Filing Summary & Sentiment
File numbers found in text: 001-34855
Letter
Mail Stop 3233 November 9, 2017 Via Email Mr. David K. Holeman Chief Financial Officer Whitestone REIT 2600 South Gessner, Suite 500 Houston, TX 77063
Re: Whitestone REIT Form 10-K Filed March 3, 2017 File No. 001-34855
Dear Mr. Holeman :
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 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 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.
Notes to Consolidated Financial Statements
Note 5. Variable Interest Entities, page F -18
1. We note from your disclosure that Pillarstone OP is determined to be a VIE, which you consolidate as a result of being the primary beneficiary as of December 31, 2016 . Please provide us with your analysis of how you determined that you are the primary benef iciary. Please cite the applicable guidance in your response.
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 s taff.
David K. Holeman Whitestone REIT November 9, 2017 Page 2
You may contact Kristi Marrone, Staff Accountant , at (202) -551-3429 or me at (202) 551 -3395 with any questions.
Sincerely,
/s/ Isaac Esquivel
Show Raw Text
Mail Stop 3233 November 9, 2017 Via Email Mr. David K. Holeman Chief Financial Officer Whitestone REIT 2600 South Gessner, Suite 500 Houston, TX 77063 Re: Whitestone REIT Form 10-K Filed March 3, 2017 File No. 001-34855 Dear Mr. Holeman : 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 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 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. Notes to Consolidated Financial Statements Note 5. Variable Interest Entities, page F -18 1. We note from your disclosure that Pillarstone OP is determined to be a VIE, which you consolidate as a result of being the primary beneficiary as of December 31, 2016 . Please provide us with your analysis of how you determined that you are the primary benef iciary. Please cite the applicable guidance in your response. 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 s taff. David K. Holeman Whitestone REIT November 9, 2017 Page 2 You may contact Kristi Marrone, Staff Accountant , at (202) -551-3429 or me at (202) 551 -3395 with any questions. Sincerely, /s/ Isaac Esquivel Isaac Esquivel Staff Accountant Office of Real Estate and Commodities