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SEC Comment Letter for Global Net Lease, Inc. (GNL, GNL-PA, GNL-PB, GNL-PD, GNL-PE) (CIK 0001526113) (GNL) — Jun 24, 2016

Global Net Lease, Inc. (GNL, GNL-PA, GNL-PB, GNL-PD, GNL-PE) (CIK 0001526113)
Date: June 24, 2016 · CIK: 0001526113 · Accession: 0000000000-16-081934

AI Filing Summary & Sentiment

Date
December 31, 2015
Author
/s/ Jennifer Monick
Form
UPLOAD
Company
Global Net Lease, Inc. (GNL, GNL-PA, GNL-PB, GNL-PD, GNL-PE) (CIK 0001526113)

Letter

Mail Stop 3233 June 24, 201 6 Via E -mail Mr. Timothy Salvemini Chief Financial Officer Global Net Lease, Inc. 405 Park Ave., 14th Floor New York , NY 10022

Re: Global Net Lease, Inc. Form 10-K for the fiscal year ended December 31, 2015 Filed February 29, 201 6 File No. 1-37390

Dear Mr. Salvemini :

We have limited our review of your filing to the financial statements and related disclosures 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 our comment 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 our comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment, we may have additional comments.

Form 10 -K for the fiscal year ended December 31, 201 5

Financial Statements

Note 8 – Derivatives and Hedging Activities, page F -27

1. We note you have recorded $5.1 million of hedge ineffectiveness in earnings during 2015. Please tell us how you considered the hedge ineffectiveness in your determination that your hedges are highly effective. Within your response, please reference the authoritative accounting literature management relied upon.

Timothy Salvemini Global Net Lease, Inc. June 24, 201 6 Page 2

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

In responding to our comment, please provide a written statement from the com pany 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 t o 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 Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 - 3295 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
/s/ Jennifer Monick

Show Raw Text
Mail Stop 3233

June 24, 201 6

Via E -mail
Mr. Timothy Salvemini
Chief Financial Officer
Global Net Lease, Inc.
405 Park Ave., 14th Floor
New York , NY  10022

Re:  Global Net Lease, Inc.
 Form 10-K for the  fiscal  year ended December  31, 2015
Filed February  29, 201 6
File No. 1-37390

Dear Mr. Salvemini :

 We have limited our review of your filing to the financial statements and related disclosures
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 our comment 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 our
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment, we may have additional comments.

Form 10 -K for the fiscal year ended December 31, 201 5

Financial Statements

Note 8 – Derivatives and Hedging Activities, page F -27

1. We note you have recorded $5.1 million of hedge ineffectiveness in earnings during
2015.  Please tell us how you considered the hedge  ineffectiveness in your determination
that your hedges are highly effective.  Within your response, please reference the
authoritative accounting literature management relied upon.

Timothy Salvemini
 Global Net Lease,  Inc.
 June 24, 201 6
 Page 2

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

 In responding to our comment, please provide a written statement from the com pany
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 t o 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 Howard Efron, Staff Accountant, at (202) 551 -3439  or me at (202) 551 -
3295 if you have questions regarding comments on the financial statements and related matters.

Sincerely,

        /s/ Jennifer Monick

Jennifer Monick
Assistant Chief Accountant
Office of Real Estate & -
    Commodities