SEC Comment Letter 0000000000-23-011755 to Apollo Commercial Real Estate Finance, Inc. (ARI) (CIK 0001467760) (ARI)
Apollo Commercial Real Estate Finance, Inc. (ARI) (CIK 0001467760)
Date: Oct. 26, 2023 · CIK: 0001467760 · Accession: 0000000000-23-011755
AI Filing Summary & Sentiment
File numbers found in text: 001-34452
Letter
United States securities and exchange commission logo October 26, 2023 Anastasia Mironova Chief Financial Officer Apollo Commercial Real Estate Finance, Inc. c/o Apollo Global Management, Inc. 9 West 57th Street , 42nd Floor New York , NY 10019 Re:Apollo Commercial Real Estate Finance, Inc. Form 10-K for the year ended December 31, 2022 Response dated October 12, 2023 File No. 001-34452 Dear Anastasia Mironova: We have reviewed your October 12, 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 September 29, 2023 letter. Form 10-K for the year ended December 31, 2022 Item 8. Financial Statements and Supplementary Data Note 4 - Commercial Mortgage Loans, Subordinate Loans and Other Lending Assets, Net Risk Rating, page 69 1.We note your response to prior comment 2. Please tell us what consideration was given to providing discussion in your Management’s Discussion and Analysis of Financial Condition and Results of Operations to further enhance a reader's understanding of your perspective of assessing risk factors of your loan portfolio and assigning a risk rating. For example, further discussion may include providing a range of loan-to-value ratios of your loan portfolio or whether any factors are more indicative of assigned risk to loans. Please refer to Item 303(a) of Regulation S-K.
FirstName LastNameAnastasia Mironova Comapany NameApollo Commercial Real Estate Finance, Inc. October 26, 2023 Page 2 FirstName LastName Anastasia Mironova Apollo Commercial Real Estate Finance, Inc. October 26, 2023 Page 2 Please contact Eric McPhee at 202-551-3693 or Isaac Esquivel at 202-551-3395 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
October 26, 2023
Anastasia Mironova
Chief Financial Officer
Apollo Commercial Real Estate Finance, Inc.
c/o Apollo Global Management, Inc.
9 West 57th Street , 42nd Floor
New York , NY 10019
Re:Apollo Commercial Real Estate Finance, Inc.
Form 10-K for the year ended December 31, 2022
Response dated October 12, 2023
File No. 001-34452
Dear Anastasia Mironova:
We have reviewed your October 12, 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 September 29,
2023 letter.
Form 10-K for the year ended December 31, 2022
Item 8. Financial Statements and Supplementary Data
Note 4 - Commercial Mortgage Loans, Subordinate Loans and Other Lending Assets, Net
Risk Rating, page 69
1.We note your response to prior comment 2. Please tell us what consideration was given to
providing discussion in your Management’s Discussion and Analysis of Financial
Condition and Results of Operations to further enhance a reader's understanding of your
perspective of assessing risk factors of your loan portfolio and assigning a risk rating. For
example, further discussion may include providing a range of loan-to-value ratios of your
loan portfolio or whether any factors are more indicative of assigned risk to loans. Please
refer to Item 303(a) of Regulation S-K.
FirstName LastNameAnastasia Mironova
Comapany NameApollo Commercial Real Estate Finance, Inc.
October 26, 2023 Page 2
FirstName LastName
Anastasia Mironova
Apollo Commercial Real Estate Finance, Inc.
October 26, 2023
Page 2
Please contact Eric McPhee at 202-551-3693 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction