SEC Comment Letter 0000000000-24-008264 to Pacific Oak Strategic Opportunity REIT, Inc. (PCOK) (CIK 0001452936) (PCOK)
Pacific Oak Strategic Opportunity REIT, Inc. (PCOK) (CIK 0001452936)
Date: July 22, 2024 · CIK: 0001452936 · Accession: 0000000000-24-008264
AI Filing Summary & Sentiment
File numbers found in text: 000-54382
Letter
July 22, 2024 Michael Bender Chief Financial Officer Pacific Oak Strategic Opportunity REIT, Inc. 11766 Wilshire Blvd. Suite 1670 Los Angeles, CA 90025 Re:Pacific Oak Strategic Opportunity REIT, Inc. Form 10-K for the Fiscal Year Ending December 31, 2023 Filed April 1, 2024 File No. 000-54382 Dear Michael Bender: 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 our 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-K for the Fiscal Year Ending December 31, 2023 10. Commitments and Contingencies Guarantee Agreements, page F-36 1.Please tell us the maximum potential amount of future payments you can owe under your guarantee of 110 William Joint Venture and revise future filings to include all disclosure required by ASC 460-10-50-4.
July 22, 2024 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. Please contact Babette Cooper at 202-551-3396 or Wilson Lee at 202-551-3468 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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July 22, 2024
Michael Bender
Chief Financial Officer
Pacific Oak Strategic Opportunity REIT, Inc.
11766 Wilshire Blvd.
Suite 1670
Los Angeles, CA 90025
Re:Pacific Oak Strategic Opportunity REIT, Inc.
Form 10-K for the Fiscal Year Ending December 31, 2023
Filed April 1, 2024
File No. 000-54382
Dear Michael Bender:
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
our 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-K for the Fiscal Year Ending December 31, 2023
10. Commitments and Contingencies
Guarantee Agreements, page F-36
1.Please tell us the maximum potential amount of future payments you can owe under your
guarantee of 110 William Joint Venture and revise future filings to include all disclosure
required by ASC 460-10-50-4.
July 22, 2024
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.
Please contact Babette Cooper at 202-551-3396 or Wilson Lee at 202-551-3468 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction