SEC Comment Letter for Brookfield Property Partners L.P. (BPYPM, BPYPN, BPYPO, BPYPP) (CIK 0001545772) (BPYPM) — Dec 5, 2016
Brookfield Property Partners L.P. (BPYPM, BPYPN, BPYPO, BPYPP) (CIK 0001545772)
Date: Dec. 5, 2016 · CIK: 0001545772 · Accession: 0000000000-16-103503
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35505
Letter
Mailstop 3233 December 5 , 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 November 7 , 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 res pond. 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 comments in our October 12 , 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 1. Based on the table at the bottom of page F-27, it appears th at your consolidated properties are made up of 10 asset classes (i.e. Office – United States, Office – Canada, etc.) to meet the disclosure requirements of IFRS 13. In future filings, please revise the fair value hierarchy table on page F -28 to disclose t he fair value at the asset class level. Further, please revise future filings to include a sensitivity analysis at the asset class level; your sensitivity analysis should be based on reasonably likely changes for each asset class. Within your response, p lease tell us what basis point change you expect to provide for each asset class. Please refer to paragraphs 93 and 94 of IFRS 13.
Mr. Bryan K. Davis Brookfield Property Partners L.P. December 5 , 2016 Page 2
You may contact Peter McPhun at 202-551-3581 or me at 202-551-3295 with any questions.
Sincerely,
/s/ Jenni fer Monick
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Mailstop 3233
December 5 , 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 November 7 , 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 res pond. 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 comments in our October 12 ,
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 1. Based on the table at the bottom of page
F-27, it appears th at your consolidated properties are made up of 10 asset classes (i.e.
Office – United States, Office – Canada, etc.) to meet the disclosure requirements of
IFRS 13. In future filings, please revise the fair value hierarchy table on page F -28 to
disclose t he fair value at the asset class level. Further, please revise future filings to
include a sensitivity analysis at the asset class level; your sensitivity analysis should be
based on reasonably likely changes for each asset class. Within your response, p lease tell
us what basis point change you expect to provide for each asset class. Please refer to
paragraphs 93 and 94 of IFRS 13.
Mr. Bryan K. Davis
Brookfield Property Partners L.P.
December 5 , 2016
Page 2
You may contact Peter McPhun at 202-551-3581 or me at 202-551-3295 with any
questions.
Sincerely,
/s/ Jenni fer Monick
Jennifer Monick
Assistant Chief Accountant
Office of Real Estate and
Commodities