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SEC Comment Letter for CIM REAL ESTATE FINANCE TRUST, INC. (CMRF) (CIK 0001498547) (CMRF) — Sep 11, 2014

CIM REAL ESTATE FINANCE TRUST, INC. (CMRF) (CIK 0001498547)
Date: Sept. 11, 2014 · CIK: 0001498547 · Accession: 0000000000-14-045688

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
September 11, 2014
Author
/s/ Kevin Woody
Form
UPLOAD
Company
CIM REAL ESTATE FINANCE TRUST, INC. (CMRF) (CIK 0001498547)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE September 11, 2014 Via e -mail Mr. Simon J. Misselbrook Chief Financial Officer Cole Credit Property Trust IV, Inc. 2325 East Camelback Road, Suite 1100 Phoenix, AZ 85016

RE: Cole Credit Property Trust IV, Inc. Form 10 -K for the Fiscal Year Ended December 31, 20 13 Filed March 31, 2014 File No. 0-54939

Dear Mr. Misselbrook :

We have reviewed your filing 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 this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provi de in response to this com ment , we may have additional comments.

Note 4 – Real Estate Acquisitions, page F -16 1. We note that you acquired 248 properties for an aggregate of $1.7 billion and 89 properties for an aggregate of $515 million during 2013 and 2012, respectively. We also note, from your Schedule III, that many of the properties have the same date acquired and that several were acquired within a short period of time. Please clarify if there were any transactions in which more than one property was acquired or if any transac tions were similarly related. If so, please tell us how you assessed materiality in the aggregate when individual properties were insignificant and the need for financial statements pursuant to Rule 3 -14 of Regulation S -X.

We urge all persons who are re sponsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing inclu des the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy

Mr. Simon J. Misselbrook Cole Credit Property Trust IV, Inc. September 11, 2014 Page 2

and adequacy of the disclosures they have made.

In responding to our commen t, please provide a written statement from the company acknowledging that

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

You may contact William Demarest, Staff Accountant, at (202) 551-3432 or me at (202) 551-3629 with any questions.

Sincerely,
/s/ Kevin Woody

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

September 11, 2014

Via e -mail
Mr. Simon J. Misselbrook
Chief Financial  Officer
Cole Credit Property Trust IV, Inc.
2325 East Camelback Road, Suite 1100
Phoenix, AZ 85016

 RE: Cole Credit Property Trust IV, Inc.
Form 10 -K for the Fiscal Year Ended December 31, 20 13
  Filed March 31, 2014
  File No. 0-54939

Dear Mr. Misselbrook :

We have reviewed your filing  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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comment applies  to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the  information  you provi de in
response to this com ment , we may have  additional comments.

Note 4 – Real Estate Acquisitions, page F -16
1. We note that you acquired 248 properties for an aggregate of $1.7 billion and 89
properties for an aggregate of $515 million during 2013 and 2012, respectively.  We also
note, from your Schedule III, that many of the properties have the same date acquired and
that several were acquired within a short period of time.  Please clarify if there were any
transactions in which more than one property was acquired or if any transac tions were
similarly related.  If so, please tell us how you assessed materiality in the aggregate when
individual properties were insignificant and the need for financial statements pursuant to
Rule 3 -14 of Regulation S -X.

 We urge all persons who are re sponsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing inclu des the  information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy

Mr. Simon J. Misselbrook
Cole Credit Property Trust IV, Inc.
September 11, 2014
Page 2

 and adequacy of the disclosures they have made.

 In responding to our commen t, please provide a written  statement from the company
acknowledging that

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company  may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact William Demarest, Staff Accountant, at (202) 551-3432 or me at (202)
551-3629  with any questions.

        Sincerely,

        /s/ Kevin Woody

        Kevin Woody
        Branch Chief