SEC Comment Letter for GLADSTONE LAND Corp (LAND, LANDO, LANDP) (CIK 0001495240) (LAND) — Nov 14, 2017
GLADSTONE LAND Corp (LAND, LANDO, LANDP) (CIK 0001495240)
Date: Nov. 14, 2017 · CIK: 0001495240 · Accession: 0000000000-17-040204
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File numbers found in text: 001-35795
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Mail Stop 3233
November 14 , 2017
Via E -mail
Lewis Parrish
Chief Financial Officer and Assistant Treasurer
Gladstone Land Corporation
1521 West Branch Drive, Suite 100
McLean, VA 22102
Re: Gladstone Land Corporation
Form 10-K for the fiscal year ended December 31, 201 6
Filed February 21, 2017
File No. 001-35795
Dear Mr. Parrish :
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested
information or advis e 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 rev iewing your response to this comment, we may have additional comments.
Form 10 -K for the year ended December 31, 2016
General
1. We note that the purchase prices of your acquisitions of the Gunbarrel Road and Citrus
Boulevard properties exceeded 10% o f your total assets as of the respective prior audited
balance sheet dates. Please tell us how you considered the need to present audited
historical financial statements for these properties in accordance with Rule 3 -14 of
Regulation S -X.
Lewis Parish
Gladstone Land Corporation
November 14, 2017
Page 2
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 Eric McPhee at (202) 551 -3693 or me at (202) 551 -3468 with any
questions.
Sincerely,
/s/ Wilson K. Lee
Wilson K. Lee
Senior Staff Accountant
Office of Real Estate and
Commodities