SEC Comment Letter for Brookfield Property Partners L.P. (BPYPM, BPYPN, BPYPO, BPYPP) (CIK 0001545772) (BPYPM) — Dec 22, 2016
Brookfield Property Partners L.P. (BPYPM, BPYPN, BPYPO, BPYPP) (CIK 0001545772)
Date: Dec. 22, 2016 · CIK: 0001545772 · Accession: 0000000000-16-106139
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35505
Letter
Mailstop 3233 December 22, 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 December 19 , 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 reference to a prior comment is to our comment in our December 5, 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 and your proposed disclosure for your sensitivity analysis. It is unclear why the 5 -15 basis point change that you propose disclosing is relevant to your asset classes because it does not appear to be based on reasonably likely changes for each asset class. Please confirm that you will further revise your sensiti vity analysis to reflect the impacts that are based on reasonably likely changes for each asset class, such as a 25 basis point change.
Mr. Bryan K. Davis Brookfield Property Partners L.P. December 22, 2016 Page 2
You may contact Peter McPhun at 202 -551-3581 or me at 202 -551-3295 with any questions.
Sincerely,
/s/ Jennifer Monick
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Mailstop 3233
December 22, 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 December 19 , 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 reference to a prior comment is to our comment in our December
5, 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 and your proposed disclosure for your
sensitivity analysis. It is unclear why the 5 -15 basis point change that you propose
disclosing is relevant to your asset classes because it does not appear to be based on
reasonably likely changes for each asset class. Please confirm that you will further revise
your sensiti vity analysis to reflect the impacts that are based on reasonably likely changes
for each asset class, such as a 25 basis point change.
Mr. Bryan K. Davis
Brookfield Property Partners L.P.
December 22, 2016
Page 2
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