SEC Comment Letter for Hudson Pacific Properties, Inc. (HPP, HPP-PC) (CIK 0001482512) (HPP) — Aug 10, 2018
Hudson Pacific Properties, Inc. (HPP, HPP-PC) (CIK 0001482512)
Date: Aug. 10, 2018 · CIK: 0001482512 · Accession: 0000000000-18-024900
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34789, 333-202799
Letter
Mailstop 3233 August 10, 201 8 Via E-mail Mr. Mark T. Lammas Chief Financial Officer Hudson Pacific Properties, Inc. Hudson Pacific Properties, L.P. 11601 Wilshire Blvd., Ninth Floor Los Angeles, CA 90025 Form 8 -K Filed August 1, 2018 File No. 001-34789 (Inc. ) File No. 333-202799 -01 (L.P.)
Re: Hudson Pacific Properties, Inc. Hudson Pacific Properties, L.P. Form 10-K for the fiscal year e nded December 31, 201 7 Filed February 16, 201 8
Dear Mr. Lammas :
We have limited our review of your filings to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments 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 comments apply to your facts and circumstances, please te ll us why in your response.
After reviewing your response to these comments, we may have additional comments.
Mr. Mark T. Lammas Hudson Pacific Properties, Inc. Hudson Pacific Properties, L.P. August 10, 201 8 Page 2
Form 8 -K filed August 1, 2018
Exhibit 99.2
1. We note on page 27 that you present Same -Store net operating income on a “GAAP” basis. We also note on page 28 that you present “Property GAAP Net Operating Income ” and “ Total GAAP Net Operating Income. ” Given that NOI is a non -GAAP measure, please revise your future filings to remove the word “GAAP" from the labeling of your non-GAAP measu res presented.
2. Please expand your presentation to separately disclose all material reconciling items between the cash basis operating measures and the non -cash basis operating measures (e.g. straight line rent adjustment, amortization of lease intangibles et c.)
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Jeffrey Lewis, Staff Accountant, at (202) 551 -6216 or the undersigned at (202) 551-3438 with any questions.
Sincerely,
/s/ Robert F. Telewicz, Jr.
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Mailstop 3233 August 10, 201 8 Via E-mail Mr. Mark T. Lammas Chief Financial Officer Hudson Pacific Properties, Inc. Hudson Pacific Properties, L.P. 11601 Wilshire Blvd., Ninth Floor Los Angeles, CA 90025 Re: Hudson Pacific Properties, Inc. Hudson Pacific Properties, L.P. Form 10-K for the fiscal year e nded December 31, 201 7 Filed February 16, 201 8 Form 8 -K Filed August 1, 2018 File No. 001-34789 (Inc. ) File No. 333-202799 -01 (L.P.) Dear Mr. Lammas : We have limited our review of your filings to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please te ll us why in your response. After reviewing your response to these comments, we may have additional comments. Mr. Mark T. Lammas Hudson Pacific Properties, Inc. Hudson Pacific Properties, L.P. August 10, 201 8 Page 2 Form 8 -K filed August 1, 2018 Exhibit 99.2 1. We note on page 27 that you present Same -Store net operating income on a “GAAP” basis. We also note on page 28 that you present “Property GAAP Net Operating Income ” and “ Total GAAP Net Operating Income. ” Given that NOI is a non -GAAP measure, please revise your future filings to remove the word “GAAP" from the labeling of your non-GAAP measu res presented. 2. Please expand your presentation to separately disclose all material reconciling items between the cash basis operating measures and the non -cash basis operating measures (e.g. straight line rent adjustment, amortization of lease intangibles et c.) We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Jeffrey Lewis, Staff Accountant, at (202) 551 -6216 or the undersigned at (202) 551-3438 with any questions. Sincerely, /s/ Robert F. Telewicz, Jr. Robert F. Telewicz, Jr. Accounting Branch Chief Office of Real Estate and Commodities