SEC Comment Letter for OFFICE PROPERTIES INCOME TRUST (OPI, OPINL) (CIK 0001456772) (OPI) — Jul 23, 2018
OFFICE PROPERTIES INCOME TRUST (OPI, OPINL) (CIK 0001456772)
Date: July 23, 2018 · CIK: 0001456772 · Accession: 0000000000-18-022489
AI Filing Summary & Sentiment
File numbers found in text: 001-34364
Letter
Mailstop 3233 July 23, 2018 Via E -mail Mark L. Kl eifges 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 Fiscal Year Ended December 31, 201 7 Filed February 27, 2018 File No. 001-34364
Dear Mr. Kleifges :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your r esponse.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for the year ended December 31, 2017
Financial Statements
Note 5. Real Estate Properties
FPO Transaction, page F -12
1. Please explain to us how you arrived at the conclusion that your acquisition of First Potomac Realty Trust should be accounted for as an asset acquisition. Your response should include, but not be limited to, the following:
Mark L. Kleifges Government Properties Income Trust July 23, 2018 Page 2
A discussion of the similarities and differences in risk pro files of single tenant, multi -tenant and business parks acquired ; A discussion of the similarities and differences in risk profiles of properties acquired based on different geographic location ; A discussion of the assembled workforce acquired from First Potomac Realty (if any) and how the acquisition of that workforce factored into your analysis.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, acti on or absence of action by the staff.
You may contact Babette Cooper, Staff Accountant, at 202 -551-3396 or me at 202 -551- 3438 if you have questions.
Sincerely,
/s/ Robert F. Telewicz, Jr.
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Mailstop 3233 July 23, 2018 Via E -mail Mark L. Kl eifges 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 Fiscal Year Ended December 31, 201 7 Filed February 27, 2018 File No. 001-34364 Dear Mr. Kleifges : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your r esponse. After reviewing your response to these comments, we may have additional comments. Form 10 -K for the year ended December 31, 2017 Financial Statements Note 5. Real Estate Properties FPO Transaction, page F -12 1. Please explain to us how you arrived at the conclusion that your acquisition of First Potomac Realty Trust should be accounted for as an asset acquisition. Your response should include, but not be limited to, the following: Mark L. Kleifges Government Properties Income Trust July 23, 2018 Page 2 A discussion of the similarities and differences in risk pro files of single tenant, multi -tenant and business parks acquired ; A discussion of the similarities and differences in risk profiles of properties acquired based on different geographic location ; A discussion of the assembled workforce acquired from First Potomac Realty (if any) and how the acquisition of that workforce factored into your analysis. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, acti on or absence of action by the staff. You may contact Babette Cooper, Staff Accountant, at 202 -551-3396 or me at 202 -551- 3438 if you have questions. Sincerely, /s/ Robert F. Telewicz, Jr. Robert F. Telewicz, Jr. Accounting Branch Chief Office of Real Estate and Commodities