Correspondence 0001104659-24-077563 from Global Medical REIT Inc. (GMRE, GMRE-PA) (CIK 0001533615) (GMRE)
Global Medical REIT Inc. (GMRE, GMRE-PA) (CIK 0001533615)
Date: July 3, 2024 · CIK: 0001533615 · Accession: 0001104659-24-077563
AI Filing Summary & Sentiment
File numbers found in text: 001-37815
Referenced dates: June 24, 2024
Letter
July 3, 2024
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549-3561
Attn: Mr. Ameen Hamady
Ms. Kristina Marrone
Re: Global Medical REIT Inc.
Form 10-K for the fiscal year ended December 31, 2023
Filed on February 28, 2024
File No. 001-37815
Ladies and Gentlemen:
Set forth below is the response of Global Medical REIT Inc. (the “Company”) to the comment received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated June 24, 2024, with respect to the Company’s Form 10-K for the fiscal year ended December 31, 2023, File No. 001-37815, filed with the Commission on February 28, 2024 (the “Form 10-K”).
For your convenience, the response is prefaced by the exact text of the Staff’s comment in bold, italicized text. All references to page numbers and captions correspond to the Form 10-K unless otherwise specified.
Form 10-K for the fiscal 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.
RESPONSE:
The Company respectfully acknowledges the Staff’s comment and advises the Staff that the Company will revise in future filings to clarify that FFO, AFFO and related per share amounts, are attributable to common stockholders and non-controlling interests. Additionally, the inconsistency in net income attributable to common stockholders per share – basic and diluted is the result of a clerical error. The face of the Consolidated Statements of Operations presents the correct amount for net income attributable to common stockholders per share - basic and diluted – for the year ended December 31, 2023 of $0.23 per share and this amount is presented correctly elsewhere in Management’s Discussion and Analysis of Financial Condition and Results of Operations. The Company will correct this clerical error in its Form 10-K for the fiscal year ended December 31, 2024.
United States Securities and Exchange Commission
Division of Corporation Finance
July 3, 2024
Page 2
If you have any questions or comments regarding the foregoing, please contact the undersigned at (202) 524-6863 or Daniel LeBey of Vinson & Elkins L.L.P. at (804) 327-6310.
Sincerely,
GLOBAL MEDICAL REIT INC.
Show Raw Text
CORRESP
1
filename1.htm
July 3, 2024
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549-3561
Attn: Mr. Ameen Hamady
Ms. Kristina Marrone
Re: Global Medical REIT Inc.
Form 10-K for the fiscal year ended December 31, 2023
Filed on February 28, 2024
File No. 001-37815
Ladies and Gentlemen:
Set forth below is the response
of Global Medical REIT Inc. (the “Company”) to the comment received from the staff of the Division of Corporation
Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
by letter dated June 24, 2024, with respect to the Company’s Form 10-K for the fiscal year ended December 31, 2023, File No. 001-37815,
filed with the Commission on February 28, 2024 (the “Form 10-K”).
For your convenience, the
response is prefaced by the exact text of the Staff’s comment in bold, italicized text. All references to page numbers and captions
correspond to the Form 10-K unless otherwise specified.
Form 10-K for the fiscal 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.
RESPONSE:
The Company
respectfully acknowledges the Staff’s comment and advises the Staff that the Company will revise in future filings to clarify
that FFO, AFFO and related per share amounts, are attributable to common stockholders and non-controlling interests. Additionally,
the inconsistency in net income attributable to common stockholders per share – basic and diluted is the result of a clerical
error. The face of the Consolidated Statements of Operations presents the correct amount for net income attributable to common
stockholders per share - basic and diluted – for the year ended December 31, 2023 of $0.23 per share and this amount is
presented correctly elsewhere in Management’s Discussion and Analysis of Financial Condition and Results of Operations. The
Company will correct this clerical error in its Form 10-K for the fiscal year ended December 31, 2024.
United States Securities and Exchange Commission
Division of Corporation Finance
July 3, 2024
Page 2
If you have any questions or
comments regarding the foregoing, please contact the undersigned at (202) 524-6863 or Daniel LeBey of Vinson & Elkins L.L.P. at (804)
327-6310.
Sincerely,
GLOBAL MEDICAL REIT INC.
/s/ Robert Kiernan
Robert Kiernan
Chief Financial Officer
cc: Jamie Barber, Secretary and General Counsel
Daniel LeBey, Vinson &
Elkins L.L.P.