SEC Comment Letter for Global Net Lease, Inc. (GNL, GNL-PA, GNL-PB, GNL-PD, GNL-PE) (CIK 0001526113) (GNL) — Jan 12, 2017
Global Net Lease, Inc. (GNL, GNL-PA, GNL-PB, GNL-PD, GNL-PE) (CIK 0001526113)
Date: Jan. 12, 2017 · CIK: 0001526113 · Accession: 0000000000-17-001277
AI Filing Summary & Sentiment
Letter
Mail Stop 3233 January 12, 2017 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 reviewed your October 21, 2016 response to our comment letter 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 this comment 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 comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to c omments in our September 28, 2016 letter .
FORM 8 -K FILED ON AUGUST 8, 2016
Exhibit 99.1
1. We have considered your response to comment two. Given the characteristics of the adjustments made to arrive at adjusted funds from operations (AFFO) and the correlation between the presented AFFO amounts to cash flow from operations, it appears AFFO can be used as a liquidity measure. Pursuant to Question 102.05 of the updated Non -GAAP Compliance and Disclosure Interpre tations issued on May 17, 2016, please revise future filings to exclude presentation of AFFO on a per share basis.
Timothy Salvemini Global Net Lease, Inc. January 12 , 2017 Page 2
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
Show Raw Text
Mail Stop 3233
January 12, 2017
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 reviewed your October 21, 2016 response to our comment letter 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 this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Unless we note otherwise, our references to prior comments are to c omments in our September
28, 2016 letter .
FORM 8 -K FILED ON AUGUST 8, 2016
Exhibit 99.1
1. We have considered your response to comment two. Given the characteristics of the
adjustments made to arrive at adjusted funds from operations (AFFO) and the correlation
between the presented AFFO amounts to cash flow from operations, it appears AFFO can
be used as a liquidity measure. Pursuant to Question 102.05 of the updated Non -GAAP
Compliance and Disclosure Interpre tations issued on May 17, 2016, please revise future
filings to exclude presentation of AFFO on a per share basis.
Timothy Salvemini
Global Net Lease, Inc.
January 12 , 2017
Page 2
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