SEC Comment Letter 0000000000-24-001583 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: Feb. 9, 2024 · CIK: 0001465740 · Accession: 0000000000-24-001583
AI Filing Summary & Sentiment
File numbers found in text: 001-34506
Letter
United States securities and exchange commission logo February 9, 2024 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 December 11, 2023 File No. 001-34506 Dear Mary Riskey: We have reviewed your December 11, 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 our 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 the comments in our November 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 have considered your response to comment 1 and your proposed disclosures related to Income Excluding Market Driven Value Changes ("IXM") within your earnings release. Your adjustments to exclude certain market-driven value changes presents income on an alternative basis. These adjustments appear to be inconsistent with Question 100.04 of the Compliance & Disclosure Interpretations on the use of Non-GAAP Financial Measures. Specifically, changing the income recognition and measurement principles required to be applied in accordance with GAAP is considered to be an individually tailored measurement principle. Please revise your non-GAAP measure to eliminate the presentation of IXM. This comment also applies to your Earnings Call Presentation.
FirstName LastNameMary Riskey Comapany NameTwo Harbors Investment Corp. February 9, 2024 Page 2 FirstName LastName Mary Riskey Two Harbors Investment Corp. February 9, 2024 Page 2 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
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United States securities and exchange commission logo
February 9, 2024
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 December 11, 2023
File No. 001-34506
Dear Mary Riskey:
We have reviewed your December 11, 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
our 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 the comments in our November 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 have considered your response to comment 1 and your proposed disclosures related to
Income Excluding Market Driven Value Changes ("IXM") within your earnings release.
Your adjustments to exclude certain market-driven value changes presents income on an
alternative basis. These adjustments appear to be inconsistent with Question 100.04 of the
Compliance & Disclosure Interpretations on the use of Non-GAAP Financial Measures.
Specifically, changing the income recognition and measurement principles required to be
applied in accordance with GAAP is considered to be an individually tailored
measurement principle. Please revise your non-GAAP measure to eliminate the
presentation of IXM. This comment also applies to your Earnings Call Presentation.
FirstName LastNameMary Riskey
Comapany NameTwo Harbors Investment Corp.
February 9, 2024 Page 2
FirstName LastName
Mary Riskey
Two Harbors Investment Corp.
February 9, 2024
Page 2
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