Correspondence 0001104659-24-053066 from Global Net Lease, Inc. (GNL)
Global Net Lease, Inc.
Date: April 26, 2024 · CIK: 0001526113 · Accession: 0001104659-24-053066
AI Filing Summary & Sentiment
File numbers found in text: 001-37390
Letter
VIA EDGAR Office of Real Estate & Construction Form 10-K for fiscal year ended December 31, 2023 Filed February 27, 2024 File No. 001-37390
Re: Global Net Lease, Inc.
Dear Mr. Cline and Mr. Rakip:
On behalf of Global Net Lease, Inc. (the “Company”), set forth below are the Company’s responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter to Christopher Masterson of the Company, dated April 16, 2024 (the “April 16th Letter”). For convenience of reference, the Staff’s comments contained in the April 16th Letter are reprinted below in bold type and are followed by the corresponding response of the Company.
Form 10-K for fiscal year ended December 31, 2023
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 15 - Segment Reporting, page F-52
1. We note that as a result of the mergers and the related strategic shift in your operations, you concluded you now operate in four reportable segments. Please revise your disclosure in future periodic filings to address the following or advise:
· Revise the title your segment measure of profit or loss to net operating income or a similarly-titled measure so as to better reflect both the revenue and property operating expense components of your segment measure; and
· We note you reconcile your segment measure of profit or loss to Net loss attributable to common stockholders, and not Net (loss) income before income tax. In future filings, revise your reconciliation to reconcile your segment measure to Net (loss) income before income tax; refer to ASC 280-10-50-30b.
Mr. Paul Cline
Mr. Mark Rakip
U.S. Securities and Exchange Commission
April 26, 2024
Page 2
The Company acknowledges the Staff’s comment and advises the Staff that it will make the requested revisions to the Company’s disclosure in the Company’s Form 10-Q for the quarter ended March 31, 2024 and in future filings with the Commission.
*************
Please feel free to contact me at (332) 265-2074 should you require additional information or have any questions.
Sincerely,
GLOBAL NET LEASE, INC.
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April 26, 2024
VIA EDGAR
Mr. Paul Cline
Mr. Mark Rakip
Office of Real Estate & Construction
U.S. Securities and Exchange Commission
Washington, D.C. 20549
Re:
Global Net Lease, Inc.
Form 10-K for fiscal year ended December 31, 2023
Filed February 27, 2024
File No. 001-37390
Dear Mr. Cline and Mr. Rakip:
On behalf of Global Net Lease, Inc. (the “Company”),
set forth below are the Company’s responses to the comments of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) contained in your letter to Christopher Masterson of the Company, dated April
16, 2024 (the “April 16th Letter”). For convenience of reference, the Staff’s comments contained
in the April 16th Letter are reprinted below in bold type and are followed by the corresponding response of the Company.
Form 10-K for fiscal year ended December 31, 2023
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 15 - Segment Reporting, page F-52
1.
We note that as a result of the mergers and the related strategic shift in your operations, you concluded you now operate in four reportable segments. Please revise your disclosure in future periodic filings to address the following or advise:
·
Revise the title your segment measure of profit or loss to net operating income or a similarly-titled measure
so as to better reflect both the revenue and property operating expense components of your segment measure; and
·
We note you reconcile your segment measure of profit or loss to Net loss attributable to common stockholders, and not Net (loss)
income before income tax. In future filings, revise your reconciliation to reconcile your segment measure to Net (loss) income before
income tax; refer to ASC 280-10-50-30b.
Mr. Paul Cline
Mr. Mark Rakip
U.S. Securities and Exchange Commission
April 26, 2024
Page 2
The Company acknowledges the Staff’s comment and advises the
Staff that it will make the requested revisions to the Company’s disclosure in the Company’s Form 10-Q for the quarter ended
March 31, 2024 and in future filings with the Commission.
*************
Please feel free to contact me at (332) 265-2074 should you require
additional information or have any questions.
Sincerely,
GLOBAL NET LEASE, INC.
By:
/s/
Christopher Masterson
Christopher Masterson
Chief Financial Officer
Cc:
Joseph A. Herz, Greenberg Traurig, LLP
William A. Staffieri, PricewaterhouseCoopers, LLP