SEC Comment Letter for PennyMac Mortgage Investment Trust (PMT, PMTU, PMTV, PMTW, PMT-PA, PMT-PB, PMT-PC) (CIK 0001464423) (PMT) — Aug 5, 2011
PennyMac Mortgage Investment Trust (PMT, PMTU, PMTV, PMTW, PMT-PA, PMT-PB, PMT-PC) (CIK 0001464423)
Date: Aug. 5, 2011 · CIK: 0001464423 · Accession: 0000000000-11-047568
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34416
Referenced dates: August 3, 2011
Letter
August 5, 2011 VIA E-Mail Ms. Anne D. McCallion Chief Financial Officer PennyMac Mortgage Investment Trust 27001 Agoura Road Calabasas, CA 91301 Re: PennyMac Mortgage Investment Trust Form 10-K for the year ended December 31, 2010 Filed on March 7, 2011 File No. 001-34416
Dear Ms. Anne D. McCallion: We have reviewed your response letter dated August 3, 2011 and have the following comments. In our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2010
Net Investment Income, pages 57 – 59
1. In the proposed disclosure in response to comment 1, we note that you briefly discuss qualitative information regarding the initia l acquisitions of mortgage loans and where they were in the resolution pr ocess. In future filings pl ease expand your disclosures to accompany this discussion with a tabular pr esentation of your loan pool acquisitions and how they are progressing through the resolution process at quarter-end.
Anne D. McCallion PennyMac Mortgage Investment Trust August 5, 2011 Page 2
2. We note your response to comment 1 and your representation that the estimated valuations and management evaluations of mort gage loans are at the pool level and that most metrics to value and monitor the loan por tfolio are only applied at the pool level. Please disclose this information in future fi lings to enable a reader to understand how management applies the key inputs in valuing your mortgage loans.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. 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. You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3413 if you have any questions regarding comments. Sincerely, /s/ Cicely LaMothe C i c e l y L a M o t h e Senior Assistant Chief Accountant
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August 5, 2011
VIA E-Mail
Ms. Anne D. McCallion Chief Financial Officer PennyMac Mortgage Investment Trust 27001 Agoura Road Calabasas, CA 91301
Re: PennyMac Mortgage Investment Trust
Form 10-K for the year ended December 31, 2010
Filed on March 7, 2011 File No. 001-34416
Dear Ms. Anne D. McCallion:
We have reviewed your response letter dated August 3, 2011 and have the following
comments. In our comments, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2010
Net Investment Income, pages 57 – 59
1. In the proposed disclosure in response to comment 1, we note that you briefly discuss
qualitative information regarding the initia l acquisitions of mortgage loans and where
they were in the resolution pr ocess. In future filings pl ease expand your disclosures to
accompany this discussion with a tabular pr esentation of your loan pool acquisitions and
how they are progressing through the resolution process at quarter-end.
Anne D. McCallion
PennyMac Mortgage Investment Trust August 5, 2011 Page 2
2. We note your response to comment 1 and your representation that the estimated
valuations and management evaluations of mort gage loans are at the pool level and that
most metrics to value and monitor the loan por tfolio are only applied at the pool level.
Please disclose this information in future fi lings to enable a reader to understand how
management applies the key inputs in valuing your mortgage loans.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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.
You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3413 if you have
any questions regarding comments.
Sincerely,
/s/ Cicely LaMothe
C i c e l y L a M o t h e Senior Assistant Chief Accountant