SEC Comment Letter for Brookfield Property Partners L.P. (BPYPM, BPYPN, BPYPO, BPYPP) (CIK 0001545772) (BPYPM) — Oct 12, 2016
Brookfield Property Partners L.P. (BPYPM, BPYPN, BPYPO, BPYPP) (CIK 0001545772)
Date: Oct. 12, 2016 · CIK: 0001545772 · Accession: 0000000000-16-096767
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35505
Letter
Mailstop 3233 October 12 , 2016 Via E -mail Mr. Bryan K. Davis Principal Financial Officer Brookfield Property Partners L.P. 73 Front Street, 5th Floor Hamilton, HM 12, Bermuda
Re: Brookfield Property Partners L.P. Form 20-F for the fiscal year ended December 31, 2015 Filed March 17, 2016 File No. 001-35505
Dear Mr. Davis :
We have reviewed your September 16, 2016 response to our comment letter and have the following comment s. 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 possibl e 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. Unless we note otherwise, our references to prior comments are to comments in our August 29, 2016 letter .
Form 20 -F for the year ended December 31, 2015
Financial statements analysis, page 60
1. We note your response to our prior comment number one. Please explain to us how you determined that a 5 basis point change in your discount and capitalization rates is appropriate for your sensitivity analysis.
2. Please tell us how you determined it was not necessary to include a sensitivity analysis based on reasonably likely changes in significant unobservable inputs used in determining your estimated current year and expected future cash flows. Please refer to paragraph 129 of IAS 1.
Mr. Bryan K. Davis Brookfield Property Partners L.P. October 12 , 2016 Page 2
Segment performance, page 68
3. We note your response to our prior comment number two. We continue t o evaluate your response.
Notes to the Consolidated Financial Statements
Note 7. Investment Properties, page F -27
4. It appears that estimated current year and expected future cash flows are used to determine the fair values of your investment properties. Please clarify for us if any inputs into your estimated current year or expected future cash flows are significant unobservable inputs. To the extent you have identified any additional inputs as significant unobservable inputs, please revise future filings to provide quantitative information about these inputs in accordance with paragraph 93(d) of IFRS 13. To the extent you have determined that there are not any additional significant unobservable inputs, please tell us how you made that determination.
You may contact Peter McPhun at 202-551-3581 or me at 202-551-3295 with any questions.
Sincerely,
/s/ Jennifer Monick
Show Raw Text
Mailstop 3233
October 12 , 2016
Via E -mail
Mr. Bryan K. Davis
Principal Financial Officer
Brookfield Property Partners L.P.
73 Front Street, 5th Floor
Hamilton, HM 12, Bermuda
Re: Brookfield Property Partners L.P.
Form 20-F for the fiscal year ended December 31, 2015
Filed March 17, 2016
File No. 001-35505
Dear Mr. Davis :
We have reviewed your September 16, 2016 response to our comment letter and have the
following comment s. 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 possibl e 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.
Unless we note otherwise, our references to prior comments are to comments in our August 29,
2016 letter .
Form 20 -F for the year ended December 31, 2015
Financial statements analysis, page 60
1. We note your response to our prior comment number one. Please explain to us how you
determined that a 5 basis point change in your discount and capitalization rates is
appropriate for your sensitivity analysis.
2. Please tell us how you determined it was not necessary to include a sensitivity analysis
based on reasonably likely changes in significant unobservable inputs used in
determining your estimated current year and expected future cash flows. Please refer to
paragraph 129 of IAS 1.
Mr. Bryan K. Davis
Brookfield Property Partners L.P.
October 12 , 2016
Page 2
Segment performance, page 68
3. We note your response to our prior comment number two. We continue t o evaluate your
response.
Notes to the Consolidated Financial Statements
Note 7. Investment Properties, page F -27
4. It appears that estimated current year and expected future cash flows are used to
determine the fair values of your investment properties. Please clarify for us if any inputs
into your estimated current year or expected future cash flows are significant
unobservable inputs. To the extent you have identified any additional inputs as
significant unobservable inputs, please revise future filings to provide quantitative
information about these inputs in accordance with paragraph 93(d) of IFRS 13. To the
extent you have determined that there are not any additional significant unobservable
inputs, please tell us how you made that determination.
You may contact Peter McPhun at 202-551-3581 or me at 202-551-3295 with any
questions.
Sincerely,
/s/ Jennifer Monick
Jennifer Monick
Assistant Chief Accountant
Office of Real Estate and
Commodities