SEC Comment Letter 0000000000-24-004373 to CIM GROUP, INC. (CMRF)
CIM GROUP, INC.
Date: April 22, 2024 · CIK: 0001498547 · Accession: 0000000000-24-004373
AI Filing Summary & Sentiment
File numbers found in text: 000-54939
Letter
United States securities and exchange commission logo April 22, 2024 Nathan D. DeBacker Chief Financial Officer CIM Real Estate Finance Trust, Inc. 2398 East Camelback Road, 4th Floor Phoenix, AZ 85016 Re:CIM Real Estate Finance Trust, Inc. Form 10-K for the Year Ended December 31, 2023 File No. 000-54939 Dear Nathan D. DeBacker: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2023 Notes to Consolidated Financial Statements Note 10 - Repurchase Facilities, Notes Payable and Credit Facilities, page F-36 1.We note that you use repurchase agreements to finance certain assets. Please consider expanding your disclosure to quantify the average quarterly balance of your repurchase agreements for each period included in your financial statements. In addition, consider quantifying the period end balance for each of those quarters, the maximum balance at any month-end and explaining the causes and business reasons for any significant variances among these amounts. 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. Please contact William Demarest at 202-551-3432 or Isaac Esquivel at 202-551-3395 with any questions.
FirstName LastNameNathan D. DeBacker Comapany NameCIM Real Estate Finance Trust, Inc. April 22, 2024 Page 2 FirstName LastName Nathan D. DeBacker CIM Real Estate Finance Trust, Inc. April 22, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
April 22, 2024
Nathan D. DeBacker
Chief Financial Officer
CIM Real Estate Finance Trust, Inc.
2398 East Camelback Road, 4th Floor
Phoenix, AZ 85016
Re:CIM Real Estate Finance Trust, Inc.
Form 10-K for the Year Ended December 31, 2023
File No. 000-54939
Dear Nathan D. DeBacker:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
Note 10 - Repurchase Facilities, Notes Payable and Credit Facilities, page F-36
1.We note that you use repurchase agreements to finance certain assets. Please consider
expanding your disclosure to quantify the average quarterly balance of your repurchase
agreements for each period included in your financial statements. In addition, consider
quantifying the period end balance for each of those quarters, the maximum balance at any
month-end and explaining the causes and business reasons for any significant variances
among these amounts.
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.
Please contact William Demarest at 202-551-3432 or Isaac Esquivel at 202-551-3395
with any questions.
FirstName LastNameNathan D. DeBacker
Comapany NameCIM Real Estate Finance Trust, Inc.
April 22, 2024 Page 2
FirstName LastName
Nathan D. DeBacker
CIM Real Estate Finance Trust, Inc.
April 22, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction