SEC Comment Letter 0000000000-24-007090 to Global Medical REIT Inc. (GMRE, GMRE-PA) (CIK 0001533615) (GMRE)
Global Medical REIT Inc. (GMRE, GMRE-PA) (CIK 0001533615)
Date: June 24, 2024 · CIK: 0001533615 · Accession: 0000000000-24-007090
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File numbers found in text: 001-37815
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United States securities and exchange commission logo
June 24, 2024
Robert Kiernan
Chief Financial Officer
Global Medical REIT Inc.
7373 Wisconsin Ave, Suite 800
Bethesda, MD 20814
Re:Global Medical REIT Inc.
Form 10-K for the year ended December 31, 2023
Filed on February 28, 2024
File No. 001-37815
Dear Robert Kiernan:
We have reviewed your filing and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the year ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 46
1.We note that you subtract preferred stock dividends from net income to arrive at your
measures of FFO and AFFO. Please revise in future filings to clarify that FFO, AFFO and
related per share amounts, are attributable to common stockholders and non-controlling
interests. In addition, explain why "net income attributable to common stockholders per
share - basic and diluted" does not agree to the amount presented on the face of the
Consolidated Statements of Operations.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact Ameen Hamady at 202-551-3891 or Kristina Marrone at 202-551-3429 if
you have questions regarding comments on the financial statements and related matters.
FirstName LastNameRobert Kiernan
Comapany NameGlobal Medical REIT Inc.
June 24, 2024 Page 2
FirstName LastName
Robert Kiernan
Global Medical REIT Inc.
June 24, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction