SEC Comment Letter 0000000000-23-012208 to MPT Operating Partnership, L.P. (CIK 0001524607)
MPT Operating Partnership, L.P. (CIK 0001524607)
Date: Nov. 7, 2023 · CIK: 0001524607 · Accession: 0000000000-23-012208
AI Filing Summary & Sentiment
File numbers found in text: 001-32559
Letter
United States securities and exchange commission logo November 7, 2023 R. Steven Hamner Chief Financial Officer Medical Properties Trust, Inc. MPT Operating Partnership, L.P. 1000 Urban Center Drive, Suite 501 Birmingham, AL 35242 Re:Medical Properties Trust, Inc. MPT Operating Partnership, L.P. Form 10-K for the Year Ended December 31, 2022 File No. 001-32559 Dear R. Steven Hamner: We have reviewed your July 18, 2023 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our July 3, 2023 letter. Form 10-K for the year ended December 31, 2022 Significant Tenants Total Assets by Operator, page 13 1.We note your response to our prior comment 1 wherein you stated that at December 31, 2022, total assets of your top five operators are generally comprised of real estate assets, mortgage loans, investments in unconsolidated real estate joint ventures, investments in unconsolidated operating entities, and other loans. We note your inclusion of a table labeled total assets by operator on page 21 of your Form 10-Q for the quarterly period ended June 30, 2023. However, we are unable to locate disclosure clarifying the nature of the assets that are associated with an operator (i.e. real estate assets, mortgage loans, investments in unconsolidated real estate joint ventures, investments in unconsolidated operating entities, and other loans). Please confirm that in future periodic filings you will include the previously requested disclosure clarifying the nature of the assets associated
FirstName LastNameR. Steven Hamner Comapany NameMedical Properties Trust, Inc. November 7, 2023 Page 2 FirstName LastName R. Steven Hamner Medical Properties Trust, Inc. November 7, 2023 Page 2 with an operator, or tell us why you believe such clarifying disclosure is not necessary. 2.Please tell us when you expect to amend your Form 10-K for the fiscal year ended December 31, 2022 to include audited financial statements of Steward Health Care System LLC as of and for the year ended December 31, 2022. Please contact Jennifer Monick at 202-551-3295 or Mark Rakip at 202-551-3573 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Kevin Hanna
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United States securities and exchange commission logo
November 7, 2023
R. Steven Hamner
Chief Financial Officer
Medical Properties Trust, Inc.
MPT Operating Partnership, L.P.
1000 Urban Center Drive, Suite 501
Birmingham, AL 35242
Re:Medical Properties Trust, Inc.
MPT Operating Partnership, L.P.
Form 10-K for the Year Ended December 31, 2022
File No. 001-32559
Dear R. Steven Hamner:
We have reviewed your July 18, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our July 3, 2023 letter.
Form 10-K for the year ended December 31, 2022
Significant Tenants
Total Assets by Operator, page 13
1.We note your response to our prior comment 1 wherein you stated that at December 31,
2022, total assets of your top five operators are generally comprised of real estate assets,
mortgage loans, investments in unconsolidated real estate joint ventures, investments in
unconsolidated operating entities, and other loans. We note your inclusion of a table
labeled total assets by operator on page 21 of your Form 10-Q for the quarterly period
ended June 30, 2023. However, we are unable to locate disclosure clarifying the nature of
the assets that are associated with an operator (i.e. real estate assets, mortgage loans,
investments in unconsolidated real estate joint ventures, investments in unconsolidated
operating entities, and other loans). Please confirm that in future periodic filings you will
include the previously requested disclosure clarifying the nature of the assets associated
FirstName LastNameR. Steven Hamner
Comapany NameMedical Properties Trust, Inc.
November 7, 2023 Page 2
FirstName LastName
R. Steven Hamner
Medical Properties Trust, Inc.
November 7, 2023
Page 2
with an operator, or tell us why you believe such clarifying disclosure is not necessary.
2.Please tell us when you expect to amend your Form 10-K for the fiscal year ended
December 31, 2022 to include audited financial statements of Steward Health Care
System LLC as of and for the year ended December 31, 2022.
Please contact Jennifer Monick at 202-551-3295 or Mark Rakip at 202-551-3573 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Kevin Hanna