SEC Comment Letter 0000000000-23-007486 to CHIMERA INVESTMENT CORP (CIM, CIMN, CIMO, CIM-PA, CIM-PB, CIM-PC, CIM-PD) (CIK 0001409493) (CIM)
CHIMERA INVESTMENT CORP (CIM, CIMN, CIMO, CIM-PA, CIM-PB, CIM-PC, CIM-PD) (CIK 0001409493)
Date: July 13, 2023 · CIK: 0001409493 · Accession: 0000000000-23-007486
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File numbers found in text: 001-33796
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United States securities and exchange commission logo
July 13, 2023
Subramaniam Viswanathan
Chief Financial Officer
Chimera Investment Corporation
630 Fifth Avenue , Ste 2400
New York, NY 10111
Re:CHIMERA INVESTMENT CORP
Form 10-K for the year ended December 31, 2022
File No. 001-33796
Dear Subramaniam Viswanathan:
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, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Earnings available for distribution, page 51
1.We note you have added transaction expenses back to GAAP Net income within your
calculation of Earnings available for distribution. Please clarify for us the nature of these
expenses. In addition, please tell us, and revise your filing to disclose, why management
believes the exclusion of these expenses provides useful information to investors. Refer
to Item 10(e) of Regulation S-K..
FirstName LastNameSubramaniam Viswanathan
Comapany NameChimera Investment Corporation
July 13, 2023 Page 2
FirstName LastName
Subramaniam Viswanathan
Chimera Investment Corporation
July 13, 2023
Page 2
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.
You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction