SEC Comment Letter 0000000000-24-003171 to ARBOR REALTY TRUST INC (ABR, ABR-PD, ABR-PE, ABR-PF) (CIK 0001253986) (ABR)
ARBOR REALTY TRUST INC (ABR, ABR-PD, ABR-PE, ABR-PF) (CIK 0001253986)
Date: March 22, 2024 · CIK: 0001253986 · Accession: 0000000000-24-003171
AI Filing Summary & Sentiment
File numbers found in text: 001-32136
Letter
United States securities and exchange commission logo March 22, 2024 Paul Elenio Chief Financial Officer Arbor Realty Trust, Inc. 333 Earle Ovington Boulevard, Suite 900 Uniondale, NY 11553 Re:Arbor Realty Trust, Inc. Form 10-K for the fiscal year ended December 31, 2023 File No. 001-32136 Dear Paul Elenio: We have limited our review of your filing to the financial statements and related disclosures 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 the fiscal year ended December 31, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 33 1.We note your discussion in your fourth quarter earnings call of your strategy of refinancing loans off your balance sheet through your capital-light agency business, and that you are continuing to focus on working through your loan book and converting your multifamily bridge loans into agency product. You also noted that when you do a bridge loan, it's clearly for the sole purpose of creating an agency loan. Please tell us what consideration you have given to discussing this strategy in detail in your periodic filings. In closing, 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. Please contact Eric McPhee at 202-551-3693 or Isaac Esquivel at 202-551-3395 with any questions.
FirstName LastNamePaul Elenio Comapany NameArbor Realty Trust, Inc. March 22, 2024 Page 2 FirstName LastName Paul Elenio Arbor Realty Trust, Inc. March 22, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
March 22, 2024
Paul Elenio
Chief Financial Officer
Arbor Realty Trust, Inc.
333 Earle Ovington Boulevard, Suite 900
Uniondale, NY 11553
Re:Arbor Realty Trust, Inc.
Form 10-K for the fiscal year ended December 31, 2023
File No. 001-32136
Dear Paul Elenio:
We have limited our review of your filing to the financial statements and related
disclosures 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 the fiscal year ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 33
1.We note your discussion in your fourth quarter earnings call of your strategy of
refinancing loans off your balance sheet through your capital-light agency business, and
that you are continuing to focus on working through your loan book and converting your
multifamily bridge loans into agency product. You also noted that when you do a bridge
loan, it's clearly for the sole purpose of creating an agency loan. Please tell us what
consideration you have given to discussing this strategy in detail in your periodic filings.
In closing, 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.
Please contact Eric McPhee at 202-551-3693 or Isaac Esquivel at 202-551-3395 with any
questions.
FirstName LastNamePaul Elenio
Comapany NameArbor Realty Trust, Inc.
March 22, 2024 Page 2
FirstName LastName
Paul Elenio
Arbor Realty Trust, Inc.
March 22, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction