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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

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-35795

Date
February 21, 2017
Author
/s/ Wilson K. Lee
Form
UPLOAD
Company
GLADSTONE LAND Corp (LAND, LANDO, LANDP) (CIK 0001495240)

Letter

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

Show Raw Text
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