SEC Comment Letter 0000000000-23-012717 to TWO HARBORS INVESTMENT CORP. (TWO, TWO-PA, TWO-PB, TWO-PC) (CIK 0001465740) (TWO)
TWO HARBORS INVESTMENT CORP. (TWO, TWO-PA, TWO-PB, TWO-PC) (CIK 0001465740)
Date: Nov. 20, 2023 · CIK: 0001465740 · Accession: 0000000000-23-012717
AI Filing Summary & Sentiment
File numbers found in text: 001-34506
Letter
United States securities and exchange commission logo November 20, 2023 Mary Riskey Chief Financial Officer Two Harbors Investment Corp. 1601 Utica Avenue South, Suite 900 St. Louis Park, Minnesota 55416 Re:Two Harbors Investment Corp. Form 10-K for the Fiscal Year Ended December 31, 2022 Form 8-K filed July 31, 2023 Response dated November 3, 2023 File No. 001-34506 Dear Mary Riskey: We have reviewed your November 3, 2023 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our October 20, 2023 letter. Form 8-K filed July 31, 2023 Exhibit 99.1 Reconciliation of GAAP to Non-GAAP Financial Information , page 11 1.We note your response to our comment 3 and your proposed revisions. Please address the following: •We refer you to your tables 1-3 within your response. Please tell us what consideration you gave to each such table representing a non-GAAP income statement. Reference is made to Questions 102.10(b) and 102.10(c) of the Non- GAAP Financial Measures Compliance and Disclosure Interpretations. •We refer you to your table 4 within your response. It appears that you intend to continue to present income excluding market-drive value changes to common stockholders within your earnings release. Please tell us what consideration you gave
FirstName LastNameMary Riskey Comapany NameTwo Harbors Investment Corp. November 20, 2023 Page 2 FirstName LastName Mary Riskey Two Harbors Investment Corp. November 20, 2023 Page 2 to such measure being a tailored accounting principle. Reference is made to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please contact Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
United States securities and exchange commission logo
November 20, 2023
Mary Riskey
Chief Financial Officer
Two Harbors Investment Corp.
1601 Utica Avenue South, Suite 900
St. Louis Park, Minnesota 55416
Re:Two Harbors Investment Corp.
Form 10-K for the Fiscal Year Ended December 31, 2022
Form 8-K filed July 31, 2023
Response dated November 3, 2023
File No. 001-34506
Dear Mary Riskey:
We have reviewed your November 3, 2023 response to our comment letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our October 20,
2023 letter.
Form 8-K filed July 31, 2023
Exhibit 99.1
Reconciliation of GAAP to Non-GAAP Financial Information , page 11
1.We note your response to our comment 3 and your proposed revisions. Please address the
following:
•We refer you to your tables 1-3 within your response. Please tell us what
consideration you gave to each such table representing a non-GAAP income
statement. Reference is made to Questions 102.10(b) and 102.10(c) of the Non-
GAAP Financial Measures Compliance and Disclosure Interpretations.
•We refer you to your table 4 within your response. It appears that you intend
to continue to present income excluding market-drive value changes to common
stockholders within your earnings release. Please tell us what consideration you gave
FirstName LastNameMary Riskey
Comapany NameTwo Harbors Investment Corp.
November 20, 2023 Page 2
FirstName LastName
Mary Riskey
Two Harbors Investment Corp.
November 20, 2023
Page 2
to such measure being a tailored accounting principle. Reference is made to Question
100.04 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
Please contact Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction