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SEC Comment Letter 0000000000-26-003695 to Sunstone Hotel Investors, Inc. (SHO)

Sunstone Hotel Investors, Inc.
Date: April 13, 2026 · CIK: 0001295810 · Accession: 0000000000-26-003695

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File numbers found in text: 001-32319

Date
April 13, 2026
Author
Division of Corporation Finance
Form
UPLOAD
Company
Sunstone Hotel Investors, Inc.

Letter

Re: Sunstone Hotel Investors, Inc. Form 10-K for the year ended December 31, 2025 Filed on February 27, 2026 Form 8-K filed on February 27, 2026 File No. 001-32319 Dear Aaron Reyes:

April 13, 2026

Aaron Reyes Chief Financial Officer Sunstone Hotel Investors, Inc. 15 Enterprise, Suite 200 Aliso Viejo, California 92656

We have reviewed your filings 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 8-K filed on February 27, 2026 Unaudited Selected Statistical and Financial Data, page 2

1. We note your presentation of Adjusted FFO Attributable to Common Stockholders per Diluted share here and as part of your 2026 Outlook. In future periodic filings, please present with equal or greater prominence the most directly comparable measure calculated in accordance with GAAP for this non-GAAP financial measure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the Division's Corporation Finance Interpretations on Non-GAAP Financial Measures. 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 Ameen Hamady at 202-551-3891 or Shannon Menjivar at 202-551-3856 if you have questions regarding comments on the financial statements and related matters. April 13, 2026 Page 2

Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

Show Raw Text
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<TEXT>
 April 13, 2026

Aaron Reyes
Chief Financial Officer
Sunstone Hotel Investors, Inc.
15 Enterprise, Suite 200
Aliso Viejo, California 92656

 Re: Sunstone Hotel Investors, Inc.
 Form 10-K for the year ended December 31, 2025
 Filed on February 27, 2026
 Form 8-K filed on February 27, 2026
 File No. 001-32319
Dear Aaron Reyes:

 We have reviewed your filings 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 8-K filed on February 27, 2026
Unaudited Selected Statistical and Financial Data, page 2

1. We note your presentation of Adjusted FFO Attributable to Common
Stockholders per
 Diluted share here and as part of your 2026 Outlook. In future periodic
filings, please
 present with equal or greater prominence the most directly comparable
measure
 calculated in accordance with GAAP for this non-GAAP financial measure.
Refer to
 Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the
Division's
 Corporation Finance Interpretations on Non-GAAP Financial Measures.
 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 Ameen Hamady at 202-551-3891 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters.
 April 13, 2026
Page 2

 Sincerely,

 Division of Corporation Finance
 Office of Real Estate & Construction
</TEXT>
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