SEC Comment Letter 0000000000-24-011535 to NorthStar Healthcare Income, Inc. (NHHS) (CIK 0001503707)
NorthStar Healthcare Income, Inc. (NHHS) (CIK 0001503707)
Date: Oct. 11, 2024 · CIK: 0001503707 · Accession: 0000000000-24-011535
AI Filing Summary & Sentiment
File numbers found in text: 000-55190
Letter
October 11, 2024 Nicholas R. Balzo Chief Financial Officer NorthStar Healthcare Income, Inc. 575 Lexington Avenue, 14th Floor New York, NY 10022 Re:NorthStar Healthcare Income, Inc. Form 10-K for the fiscal year ended December 31, 2023 Form 10-Q for the quarterly period ended September 30, 2023 File No. 000-55190 Dear Nicholas R. Balzo: We have limited our review of your filings to the financial statements and related disclosures and have the following comments. 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 Item 9A. Controls and Procedures Internal Control over Financial Reporting, page 90 1.Please amend your filing to provide management's annual report on internal control over financial reporting as of December 31, 2023. Please ensure that your disclosure complies with Item 308(a) of Regulation S-K including disclosing the framework used by management. Form 10-Q for the quarterly period ended September 30, 2023 Item 5. Other Information Determination of Estimated Value Per Share, page 54 We note your disclosure of estimated value per share of $2.64 as of June 30, 2023. Please expand your disclosure to include the following: •a comparative breakdown for any prior period value estimate;2.
October 11, 2024 Page 2 •an explanation for the changes in your estimated net asset value (NAV); •a list of historical NAV calculations; and, •the relationship between the aggregate purchase price of your properties (as adjusted for related capital expenditures) and the value assigned to your properties. 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 Jeffrey Lewis at 202-551-6216 or Isaac Esquivel at 202-551-3395 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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October 11, 2024
Nicholas R. Balzo
Chief Financial Officer
NorthStar Healthcare Income, Inc.
575 Lexington Avenue, 14th Floor
New York, NY 10022
Re:NorthStar Healthcare Income, Inc.
Form 10-K for the fiscal year ended December 31, 2023
Form 10-Q for the quarterly period ended September 30, 2023
File No. 000-55190
Dear Nicholas R. Balzo:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comments.
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
Item 9A. Controls and Procedures
Internal Control over Financial Reporting, page 90
1.Please amend your filing to provide management's annual report on internal control
over financial reporting as of December 31, 2023. Please ensure that your disclosure
complies with Item 308(a) of Regulation S-K including disclosing the framework
used by management.
Form 10-Q for the quarterly period ended September 30, 2023
Item 5. Other Information
Determination of Estimated Value Per Share, page 54
We note your disclosure of estimated value per share of $2.64 as of June 30, 2023.
Please expand your disclosure to include the following:
•a comparative breakdown for any prior period value estimate;2.
October 11, 2024
Page 2
•an explanation for the changes in your estimated net asset value (NAV);
•a list of historical NAV calculations; and,
•the relationship between the aggregate purchase price of your properties (as
adjusted for related capital expenditures) and the value assigned to your
properties.
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 Jeffrey Lewis at 202-551-6216 or Isaac Esquivel at 202-551-3395 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction