SEC Comment Letter 0000000000-22-013144 to STARWOOD PROPERTY TRUST, INC. (STWD) (CIK 0001465128) (STWD)
STARWOOD PROPERTY TRUST, INC. (STWD) (CIK 0001465128)
Date: Dec. 6, 2022 · CIK: 0001465128 · Accession: 0000000000-22-013144
AI Filing Summary & Sentiment
File numbers found in text: 001-34436
Letter
United States securities and exchange commission logo December 6, 2022 Rina Paniry Chief Financial Officer STARWOOD PROPERTY TRUST, INC. 591 West Putnam Avenue Greenwich, Connecticut 06830 Re:STARWOOD PROPERTY TRUST, INC. Form 10-K for the year ended December 31, 2021 Filed February 25, 2022 File No. 001-34436 Dear Rina Paniry: We have reviewed your October 18, 2022 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 business days by providing the requested information or advise 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 to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 5, 2022 letter. Form 10-K for the year ended December 31, 2021 Non-GAAP Financial Measures, page 76 1.We note your response to comment 1 and that the presentation of Distributable Earnings (DE) is intended to eliminate differences between DE and taxable income. Please provide a comparison of DE to taxable income for the years ended December 2020 and 2021 and a comparison of DE to estimated taxable income for the period ended September 30, 2022. To the extent historical and estimated taxable income differs from DE please explain to us the material differences. You may contact William Demarest, Staff Accountant at 202-551-3432 or Shannon Menjivar, Accounting Branch Chief at 202-551-3856 if you have any questions.
FirstName LastNameRina Paniry Comapany NameSTARWOOD PROPERTY TRUST, INC. December 6, 2022 Page 2 FirstName LastName Rina Paniry STARWOOD PROPERTY TRUST, INC. December 6, 2022 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Michael McTiernan
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United States securities and exchange commission logo
December 6, 2022
Rina Paniry
Chief Financial Officer
STARWOOD PROPERTY TRUST, INC.
591 West Putnam Avenue
Greenwich, Connecticut 06830
Re:STARWOOD PROPERTY TRUST, INC.
Form 10-K for the year ended December 31, 2021
Filed February 25, 2022
File No. 001-34436
Dear Rina Paniry:
We have reviewed your October 18, 2022 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 business days by providing the requested
information or advise 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 to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
October 5, 2022 letter.
Form 10-K for the year ended December 31, 2021
Non-GAAP Financial Measures, page 76
1.We note your response to comment 1 and that the presentation of Distributable Earnings
(DE) is intended to eliminate differences between DE and taxable income. Please provide
a comparison of DE to taxable income for the years ended December 2020 and 2021 and a
comparison of DE to estimated taxable income for the period ended September 30, 2022.
To the extent historical and estimated taxable income differs from DE please explain to us
the material differences.
You may contact William Demarest, Staff Accountant at 202-551-3432 or Shannon
Menjivar, Accounting Branch Chief at 202-551-3856 if you have any questions.
FirstName LastNameRina Paniry
Comapany NameSTARWOOD PROPERTY TRUST, INC.
December 6, 2022 Page 2
FirstName LastName
Rina Paniry
STARWOOD PROPERTY TRUST, INC.
December 6, 2022
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Michael McTiernan