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
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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