SEC Comment Letter for PennyMac Mortgage Investment Trust (PMT, PMTU, PMTV, PMTW, PMT-PA, PMT-PB, PMT-PC) (CIK 0001464423) (PMT) — Sep 16, 2013
PennyMac Mortgage Investment Trust (PMT, PMTU, PMTV, PMTW, PMT-PA, PMT-PB, PMT-PC) (CIK 0001464423)
Date: Sept. 16, 2013 · CIK: 0001464423 · Accession: 0000000000-13-050788
AI Filing Summary & Sentiment
Reasoning
Letter
September 16, 2013 Via Email Ms. Anne D. McCallion Chief Financial Officer PennyMac Mortgage Investment Trust 6101 Condor Drive Moorpark, CA 93021 Form 10 -Q Filed May 10, 2013 File No. 001 -34416
Re: PennyMac Mortgage Investment Trust Form 10-K Filed February 28, 2013 File No. 001 -34416
Dear Ms. McCallion :
We have reviewed your correspondence dated August 16 , 2013 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 letter within ten business days by amending your filing s, by providing the requested information, or by advising us when you will pr ovide the requested response. If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment s to your filing s and the informati on you provide in response to this comment , we may have additional comments.
Form 10 -K for the year ended December 31, 2012
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 51
Net Gain (Los s) on Investments, page 75
1. We note your response to comment 2 and proposed revisions. As previously requested, please include a discussion of how the information presented should be used in understanding any trends and success rates of your modification programs and their
Anne D. McCallion PennyMac Mortgage Investment Trust September 16, 2013 Page 2
ability to generate cash flows from your nonperforming loan portfolio for each period presented.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s inclu de the information the Securities Exchange Act of 1934 and all applicable Exchange 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 adequac y of the disclosures they have made.
You may contact Kristi Marrone at (202) 551 -3429 or me at (202) 551 -3413 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Cicely LaMothe
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September 16, 2013 Via Email Ms. Anne D. McCallion Chief Financial Officer PennyMac Mortgage Investment Trust 6101 Condor Drive Moorpark, CA 93021 Re: PennyMac Mortgage Investment Trust Form 10-K Filed February 28, 2013 File No. 001 -34416 Form 10 -Q Filed May 10, 2013 File No. 001 -34416 Dear Ms. McCallion : We have reviewed your correspondence dated August 16 , 2013 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 letter within ten business days by amending your filing s, by providing the requested information, or by advising us when you will pr ovide the requested response. If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment s to your filing s and the informati on you provide in response to this comment , we may have additional comments. Form 10 -K for the year ended December 31, 2012 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 51 Net Gain (Los s) on Investments, page 75 1. We note your response to comment 2 and proposed revisions. As previously requested, please include a discussion of how the information presented should be used in understanding any trends and success rates of your modification programs and their Anne D. McCallion PennyMac Mortgage Investment Trust September 16, 2013 Page 2 ability to generate cash flows from your nonperforming loan portfolio for each period presented. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s inclu de the information the Securities Exchange Act of 1934 and all applicable Exchange 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 adequac y of the disclosures they have made. You may contact Kristi Marrone at (202) 551 -3429 or me at (202) 551 -3413 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Cicely LaMothe Cicely LaMothe Senior Assistant Chief Accountant