SEC Comment Letter for OFFICE PROPERTIES INCOME TRUST (OPI, OPINL) (CIK 0001456772) (OPI) — Aug 20, 2018
OFFICE PROPERTIES INCOME TRUST (OPI, OPINL) (CIK 0001456772)
Date: Aug. 20, 2018 · CIK: 0001456772 · Accession: 0000000000-18-025702
AI Filing Summary & Sentiment
File numbers found in text: 001-34364
Letter
Mailstop 3233 August 20 , 2018 Via E -mail Mark L. Kleifges 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 reviewed your August 1, 2018 response to our comment letter 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 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 re sponse to th is comment , 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. We note your response to comment one of our letter dated July 23 , 2018 stating that First Potomac (FPO) terminated its employees immediately preceding the acquisition and you did not acquire an assembled workforce. Please tell us if any of the FPO employees were
Mark L. Kleifges Government Properties Income Trust August 20 , 2018 Page 2
hired by your external manager, RMR LLC. To the extent employees of FPO were hired by your external manager at the time of acquisition, please address the following: Tell us if RMR LLC hired the employees responsible for leasing, tenant management, and managing and supervising your operational processes Tell us if the employees are considered critical to the creation of outputs
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 Babette Cooper, Staff Accountant, at 202 -551-3396 or me at 202 -551- 3438 if you have questions.
Sincerely,
/s/ Jennifer Monick for
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Mailstop 3233 August 20 , 2018 Via E -mail Mark L. Kleifges 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 reviewed your August 1, 2018 response to our comment letter 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 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 re sponse to th is comment , 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. We note your response to comment one of our letter dated July 23 , 2018 stating that First Potomac (FPO) terminated its employees immediately preceding the acquisition and you did not acquire an assembled workforce. Please tell us if any of the FPO employees were Mark L. Kleifges Government Properties Income Trust August 20 , 2018 Page 2 hired by your external manager, RMR LLC. To the extent employees of FPO were hired by your external manager at the time of acquisition, please address the following: Tell us if RMR LLC hired the employees responsible for leasing, tenant management, and managing and supervising your operational processes Tell us if the employees are considered critical to the creation of outputs 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 Babette Cooper, Staff Accountant, at 202 -551-3396 or me at 202 -551- 3438 if you have questions. Sincerely, /s/ Jennifer Monick for Robert Telewicz, Jr. Accounting Branch Chief Office of Real Estate and Commodities