SEC Comment Letter 0000000000-23-004446 to SL GREEN OPERATING PARTNERSHIP, L.P. (CIK 0001492869)
SL GREEN OPERATING PARTNERSHIP, L.P. (CIK 0001492869)
Date: May 1, 2023 · CIK: 0001492869 · Accession: 0000000000-23-004446
AI Filing Summary & Sentiment
File numbers found in text: 333-167793
Letter
United States securities and exchange commission logo May 1, 2023 Matthew DiLiberto Chief Financial Officer SL GREEN REALTY CORP One Vanderbilt Avenue New York, NY 10017 Re:SL GREEN REALTY CORP Form 10-K for the year ended December 31, 2022 Filed February 17, 2023 File No. 001-13199color:white;"_ SL Green Operating Partnership, L.P. Form 10-K for the year ended December 31, 2022 Filed February 17, 2023 333-167793-02 Dear Matthew DiLiberto: We have limited our review of your filing to the financial statements and related disclosures 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 our 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 our comment, we may have additional comments. Form 10-K for the year ended December 31, 2022 2022 Acquisitions, page 90 1.We note your disclosure of the acquisition of 245 Park Avenue with a gross asset valuation of approximately $2 billion. It does not appear that financial statements and related pro forma financial information have ever been filed for this acquisition. Please clarify how you considered Rule 3-14 and Article 11 of Regulation S-X in determining that such financial statements and associated pro forma financial information are not required. Your response should include your detailed calculations of significance. Specifically, within your significance calculation, please highlight how the assumed debt
FirstName LastNameMatthew DiLiberto Comapany NameSL GREEN REALTY CORP May 1, 2023 Page 2 FirstName LastName Matthew DiLiberto SL GREEN REALTY CORP May 1, 2023 Page 2 secured by the acquired property factored into your calculation pursuant to the guidance in paragraph (b)(2)(ii) of Rule 3-14 of Regulation S-X. In closing, 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 Howard Efron at (202) 551-3439 or Wilson Lee at (202) 551-3468 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
United States securities and exchange commission logo
May 1, 2023
Matthew DiLiberto
Chief Financial Officer
SL GREEN REALTY CORP
One Vanderbilt Avenue
New York, NY 10017
Re:SL GREEN REALTY CORP
Form 10-K for the year ended December 31, 2022
Filed February 17, 2023
File No. 001-13199color:white;"_
SL Green Operating Partnership, L.P.
Form 10-K for the year ended December 31, 2022
Filed February 17, 2023
333-167793-02
Dear Matthew DiLiberto:
We have limited our review of your filing to the financial statements and related
disclosures 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 our 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 our comment, we may have additional comments.
Form 10-K for the year ended December 31, 2022
2022 Acquisitions, page 90
1.We note your disclosure of the acquisition of 245 Park Avenue with a gross asset
valuation of approximately $2 billion. It does not appear that financial statements and
related pro forma financial information have ever been filed for this acquisition. Please
clarify how you considered Rule 3-14 and Article 11 of Regulation S-X in determining
that such financial statements and associated pro forma financial information are not
required. Your response should include your detailed calculations of significance.
Specifically, within your significance calculation, please highlight how the assumed debt
FirstName LastNameMatthew DiLiberto
Comapany NameSL GREEN REALTY CORP
May 1, 2023 Page 2
FirstName LastName
Matthew DiLiberto
SL GREEN REALTY CORP
May 1, 2023
Page 2
secured by the acquired property factored into your calculation pursuant to the guidance in
paragraph (b)(2)(ii) of Rule 3-14 of Regulation S-X.
In closing, 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 Howard Efron at (202) 551-3439 or Wilson Lee at (202) 551-3468 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction