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UPLOAD Filing

Sterling Real Estate Trust (CIK 0001412502)
Date: Sept. 17, 2025 · CIK: 0001412502 · Accession: 0000000000-25-010127

AI Filing Summary & Sentiment

File numbers found in text: 000-54295

Date
September 17, 2025
Author
Division of
Form
UPLOAD
Company
Sterling Real Estate Trust (CIK 0001412502)

Letter

Re: Sterling Real Estate Trust Form 10-K for the Year Ended December 31, 2024 Form 10-Q For the Quarterly Period Ended June 30, 2025 File No. 000-54295 Dear Megan E. Schreiner:

September 17, 2025

Megan E. Schreiner Interim Chief Financial Officer Sterling Real Estate Trust d/b/a Sterling Multifamily Trust 4340 18th Ave S., Suite 200 Fargo, ND 58103

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-Q For the Quarterly Period Ended June 30, 2025 Liquidity and Capital Resources, page 43

1. We note your disclosure here, and in Note 7, with regard to your lines of credit. Please address the following: You indicate that you have a $19.8 million line of credit with Gate City Bank expiring July 2025, while in Note 7 you indicate the expiration date is September 2025, and in the 10-K for the year ended December 31, 2024, you indicate that the line is $14.8 million, expiring in July 2029. Please clarify the amount of the line and when it expires. To the extent your line of credit with Gate City Bank expires within the next 12 months, please tell us and revise your discussion of liquidity in future filings to address how you intend to repay the line at its expiration date. We note that you began to carry a balance on your lines of credit in the 2nd quarter of 2024, and then draws have increased through the first 2 quarters of September 17, 2025 Page 2

2025. Please tell us if you believe your change in the utilization of your lines of credit represents a strategic shift in your financing strategy, or if you still consider these lines of credit as a means to enhance treasury management activities and more effectively manage cash balances.

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 Wilson Lee at 202-551-3468 with any questions.

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

Show Raw Text
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<TEXT>
 September 17, 2025

Megan E. Schreiner
Interim Chief Financial Officer
Sterling Real Estate Trust
d/b/a Sterling Multifamily Trust
4340 18th Ave S., Suite 200
Fargo, ND 58103

 Re: Sterling Real Estate Trust
 Form 10-K for the Year Ended December 31, 2024
 Form 10-Q For the Quarterly Period Ended June 30, 2025
 File No. 000-54295
Dear Megan E. Schreiner:

 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-Q For the Quarterly Period Ended June 30, 2025
Liquidity and Capital Resources, page 43

1. We note your disclosure here, and in Note 7, with regard to your lines
of credit. Please
 address the following:
 You indicate that you have a $19.8 million line of credit with Gate
City Bank
 expiring July 2025, while in Note 7 you indicate the expiration date
is September
 2025, and in the 10-K for the year ended December 31, 2024, you
indicate that the
 line is $14.8 million, expiring in July 2029. Please clarify the
amount of the line
 and when it expires.
 To the extent your line of credit with Gate City Bank expires within
the next 12
 months, please tell us and revise your discussion of liquidity in
future filings to
 address how you intend to repay the line at its expiration date.
 We note that you began to carry a balance on your lines of credit in
the 2nd
 quarter of 2024, and then draws have increased through the first 2
quarters of
 September 17, 2025
Page 2

 2025. Please tell us if you believe your change in the utilization of
your lines of
 credit represents a strategic shift in your financing strategy, or if
you still consider
 these lines of credit as a means to enhance treasury management
activities and
 more effectively manage cash balances.

 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 Wilson Lee at 202-551-3468
with any
questions.

 Sincerely,

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