SEC Comment Letter for OFFICE PROPERTIES INCOME TRUST (OPI, OPINL) (CIK 0001456772) (OPI) — Jul 22, 2015
OFFICE PROPERTIES INCOME TRUST (OPI, OPINL) (CIK 0001456772)
Date: July 22, 2015 · CIK: 0001456772 · Accession: 0000000000-15-038010
AI Filing Summary & Sentiment
Letter
July 22, 2015 Via E-mail Mr. Mark L. Kleifges Treasurer and Chief Financial Officer Government Properties Income Trust Two Newton Place, 255 Washington Street, Suite 300 Newton, Massachusetts 02458 -1634
Re: Government Properties Income Trust Form 10-K for the year ended December 31, 2014 Filed on February 20, 201 5 File No. 001 -34364
Dear Mr. Kleifges:
We have reviewed your filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better unders tand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 and any amendment you may file in response to th is comment , we may have additional comments.
Form 10 -Q for the period ended March 31, 2015
Note 11. Equity Investment in Select Income REIT, page 11
1) Please tell us how the company considered the recognized loss upon issuance of shares by an equity investee when performing their periodic evaluation of the equity investment in SIR for possible indictors of other than temporary impairment.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please p rovide a written statement from the company acknowledging that:
Mr. Mark L. Kleifges Government Properties Income Trust July 22, 2015 Page 2
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commissio n from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Shannon So botka, Staff Accountant at 202-551-3856 or me at 202-551- 3629 if you have questions.
Sincerely,
/s/ Kevin Woody
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July 22, 2015 Via E-mail Mr. Mark L. Kleifges Treasurer and Chief Financial Officer Government Properties Income Trust Two Newton Place, 255 Washington Street, Suite 300 Newton, Massachusetts 02458 -1634 Re: Government Properties Income Trust Form 10-K for the year ended December 31, 2014 Filed on February 20, 201 5 File No. 001 -34364 Dear Mr. Kleifges: We have reviewed your filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better unders tand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 and any amendment you may file in response to th is comment , we may have additional comments. Form 10 -Q for the period ended March 31, 2015 Note 11. Equity Investment in Select Income REIT, page 11 1) Please tell us how the company considered the recognized loss upon issuance of shares by an equity investee when performing their periodic evaluation of the equity investment in SIR for possible indictors of other than temporary impairment. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please p rovide a written statement from the company acknowledging that: Mr. Mark L. Kleifges Government Properties Income Trust July 22, 2015 Page 2 the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commissio n from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Shannon So botka, Staff Accountant at 202-551-3856 or me at 202-551- 3629 if you have questions. Sincerely, /s/ Kevin Woody Kevin R. Woody Branch Chief