SEC Comment Letter for Global Net Lease, Inc. (GNL, GNL-PA, GNL-PB, GNL-PD, GNL-PE) (CIK 0001526113) (GNL) — Sep 28, 2016
Global Net Lease, Inc. (GNL, GNL-PA, GNL-PB, GNL-PD, GNL-PE) (CIK 0001526113)
Date: Sept. 28, 2016 · CIK: 0001526113 · Accession: 0000000000-16-095032
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Mail Stop 3233
September 28, 2016
VIA E -MAIL
Mr. Timothy Salvemini
Chief Financial Officer
Global Net Lease, Inc.
405 Park Avenue, 14th Floor
New York, New York 10022
Re: Global Net Lease, Inc.
Form 8-K dated August 8, 2016
Filed August 8, 2016
File No. 001 -37390
Dear Mr. Salvemini :
We have limited our review of your filing to those issues we have addressed in our
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
FORM 8 -K FILE D ON AUGUST 8, 2016
Exhibit 99.1
1. Please explain to us the rationale for adjusting for unrealized gains and losses on foreign
currency transactions in arriving at AFFO.
Timothy Salvemini
Global Net Lease, Inc.
September 28, 201 6
Page 2
2. On page 12 you explain that excluding non -cash income and expense items from AFFO
provides useful information regarding income and expense items which have no cash
impact and do not provide liquidity to the company or require capital resources of the
company. This strongly implies that AFFO is a liquidity measure. Please explain to us
why you believe it is appropriate to present this measure on a per share basis. See
Question 102.05 of the updated Non-GAAP Compliance and Disclosure Interpretations
issued on May 17, 2016.
3. In your next earnings release, please provide a substantive and concise discussion of why
Cash NOI is useful to investors. Please provide us with your proposed changes in your
response letter .
We urge all persons who are responsible for t he 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 company and its management are
in possession of al l 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 comments, please provide a written statement from the company
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 to the filing; and
the company may not as sert 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 Wilson K. Lee at (202) 551 – 3468, Lyn Shenk at (202) 551 – 3380, or
me at (202) 551 - 3486 with any questions.
Sincerely,
/s/ Daniel L. Gordon
Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities