SEC Comment Letter for Ares Real Estate Income Trust Inc. (ZARE) (CIK 0001327978) (ZARE) — Oct 14, 2022
Ares Real Estate Income Trust Inc. (ZARE) (CIK 0001327978)
Date: Oct. 14, 2022 · CIK: 0001327978 · Accession: 0000000000-22-011340
AI Filing Summary & Sentiment
File numbers found in text: 000-52596
Letter
United States securities and exchange commission logo October 14, 2022 Lainie Minnick Chief Financial Officer Ares Real Estate Income Trust Inc. One Tabor Center 1200 Seventeenth Street, Suite 2900 Denver, CO 80202 Re:Ares Real Estate Income Trust Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed March 14, 2022 File No. 000-52596 Dear Lainie Minnick: 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 business days by providing the requested information or advise 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. Form 10-K for the Year Ended December 31, 2021 Additional Measures of Performance Net Income and NOI, page 75 1.We note that your disclosure under this heading references the reconciliation on page 72, which appears to be in the form of a full non-GAAP income statement. In future periodic filings, to avoid a non-GAAP prominence issue, please include a reconciliation that begins with the most directly comparable GAAP measure, which appears to be Net income, and reconciles down to NOI. Refer to Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. 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.
FirstName LastNameLainie Minnick Comapany NameAres Real Estate Income Trust Inc. October 14, 2022 Page 2 FirstName LastName Lainie Minnick Ares Real Estate Income Trust Inc. October 14, 2022 Page 2 You may contact William Demarest, Staff Accountant at 202-551-3432 or Isaac Esquivel, Staff Accountant at 202-551-3395 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Christopher Stambaugh
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United States securities and exchange commission logo
October 14, 2022
Lainie Minnick
Chief Financial Officer
Ares Real Estate Income Trust Inc.
One Tabor Center
1200 Seventeenth Street, Suite 2900
Denver, CO 80202
Re:Ares Real Estate Income Trust Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed March 14, 2022
File No. 000-52596
Dear Lainie Minnick:
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 business days by providing the requested
information or advise 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.
Form 10-K for the Year Ended December 31, 2021
Additional Measures of Performance
Net Income and NOI, page 75
1.We note that your disclosure under this heading references the reconciliation on page 72,
which appears to be in the form of a full non-GAAP income statement. In future periodic
filings, to avoid a non-GAAP prominence issue, please include a reconciliation that begins
with the most directly comparable GAAP measure, which appears to be Net income, and
reconciles down to NOI. Refer to Question 102.10 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations.
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.
FirstName LastNameLainie Minnick
Comapany NameAres Real Estate Income Trust Inc.
October 14, 2022 Page 2
FirstName LastName
Lainie Minnick
Ares Real Estate Income Trust Inc.
October 14, 2022
Page 2
You may contact William Demarest, Staff Accountant at 202-551-3432 or Isaac
Esquivel, Staff Accountant at 202-551-3395 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Christopher Stambaugh