SEC Comment Letter 0000000000-24-000806 to JLL Income Property Trust, Inc. (CIK 0001314152)
JLL Income Property Trust, Inc. (CIK 0001314152)
Date: Jan. 22, 2024 · CIK: 0001314152 · Accession: 0000000000-24-000806
AI Filing Summary & Sentiment
File numbers found in text: 000-51948
Letter
United States securities and exchange commission logo January 22, 2024 Gregory Falk Chief Financial Officer JLL Income Property Trust, Inc. 333 West Wacker Drive Chicago IL, 60606 Re:JLL Income Property Trust, Inc. Form 10-K for the year ended December 31, 2022 File No. 000-51948 Dear Gregory Falk : We have reviewed your January 8, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our December 22, 2023 letter. Form 10-K for the year ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Funds from Operations Reconciliation of NAREIT FFO to AFFO, page 79 1.We have reviewed your response to comment 1. It appears that the performance fees are compensation to LaSalle Investment Management, Inc. for services it provides under the advisory agreement. It appears your exclusion of the performance fees from your presentation of Adjusted Funds from Operations ("AFFO") is inconsistent with Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations, as the performance fees appear to represent a normal, recurring, cash operating expense necessary to operate your business. Please revise your calculation of AFFO to omit the adjustment for the performance fees. Please contact Paul Cline at 202-551-3851 or Jennifer Monick at 202-551-3295 if you
FirstName LastNameGregory Falk Comapany NameJLL Income Property Trust, Inc. January 22, 2024 Page 2 FirstName LastName Gregory Falk JLL Income Property Trust, Inc. January 22, 2024 Page 2 have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
January 22, 2024
Gregory Falk
Chief Financial Officer
JLL Income Property Trust, Inc.
333 West Wacker Drive
Chicago IL, 60606
Re:JLL Income Property Trust, Inc.
Form 10-K for the year ended December 31, 2022
File No. 000-51948
Dear Gregory Falk :
We have reviewed your January 8, 2024 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our December 22, 2023
letter.
Form 10-K for the year ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Funds from Operations
Reconciliation of NAREIT FFO to AFFO, page 79
1.We have reviewed your response to comment 1. It appears that the performance fees
are compensation to LaSalle Investment Management, Inc. for services it provides under
the advisory agreement. It appears your exclusion of the performance fees from your
presentation of Adjusted Funds from Operations ("AFFO") is inconsistent with Question
100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations,
as the performance fees appear to represent a normal, recurring, cash operating expense
necessary to operate your business. Please revise your calculation of AFFO to omit the
adjustment for the performance fees.
Please contact Paul Cline at 202-551-3851 or Jennifer Monick at 202-551-3295 if you
FirstName LastNameGregory Falk
Comapany NameJLL Income Property Trust, Inc.
January 22, 2024 Page 2
FirstName LastName
Gregory Falk
JLL Income Property Trust, Inc.
January 22, 2024
Page 2
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction