SEC Comment Letter for Whitestone REIT (WSR) (CIK 0001175535) (WSR) — Aug 28, 2018
Whitestone REIT (WSR) (CIK 0001175535)
Date: Aug. 28, 2018 · CIK: 0001175535 · Accession: 0000000000-18-026675
AI Filing Summary & Sentiment
Letter
Mail Stop 3233 August 27, 2018 Via Email Mr. David K. Holeman Chief Financial Officer Whitestone REIT 2600 South Gessner, Suite 500 Houston, TX 77063
Re: Whitestone REIT Form 10-Q Filed August 9, 2018 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 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 6. Investment in Real Estate Partnership, page 13
1. We note your determination that t he Contribution in December 2016 did not meet the requirements for derecognition of the underlying assets. Please provide us with a detailed analysis of how you reached your conclusion for the period beginning on January 1, 2018, citing relevant accountin g literature.
Item 4. Controls and Procedures, page 52
2. Please tell us how you considered the identification and correction of the accounting errors related to the consolidation of Pillarstone OP in your conclusion that your disclosure controls and proced ures and internal control over financial reporting were effective as of June 30, 2018 and December 31, 2017.
David K. Holeman Whitestone REIT August 27, 2018 Page 2
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 Kristi Marrone at (202) 551 -3429 or me at (202) 551 -3395 with any questions.
Sincerely,
/s/ Isaac Esquivel
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Mail Stop 3233 August 27, 2018 Via Email Mr. David K. Holeman Chief Financial Officer Whitestone REIT 2600 South Gessner, Suite 500 Houston, TX 77063 Re: Whitestone REIT Form 10-Q Filed August 9, 2018 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 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 6. Investment in Real Estate Partnership, page 13 1. We note your determination that t he Contribution in December 2016 did not meet the requirements for derecognition of the underlying assets. Please provide us with a detailed analysis of how you reached your conclusion for the period beginning on January 1, 2018, citing relevant accountin g literature. Item 4. Controls and Procedures, page 52 2. Please tell us how you considered the identification and correction of the accounting errors related to the consolidation of Pillarstone OP in your conclusion that your disclosure controls and proced ures and internal control over financial reporting were effective as of June 30, 2018 and December 31, 2017. David K. Holeman Whitestone REIT August 27, 2018 Page 2 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 Kristi Marrone 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