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SEC Comment Letter 0000000000-24-010490 to Peakstone Realty Trust (PKST) (CIK 0001600626) (PKST)

Peakstone Realty Trust (PKST) (CIK 0001600626)
Date: Sept. 17, 2024 · CIK: 0001600626 · Accession: 0000000000-24-010490

AI Filing Summary & Sentiment

File numbers found in text: 001-41686

Date
September 17, 2024
Author
Not clearly detected
Form
UPLOAD
Company
Peakstone Realty Trust (PKST) (CIK 0001600626)

Letter

September 17, 2024 Javier Bitar Chief Financial Officer and Treasurer Peakstone Realty Trust 1520 E. Grand Avenue El Segundo, CA 90245 Re:Peakstone Realty Trust Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-41686 Dear Javier Bitar: We have reviewed your filing and have the following comments. 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 Fiscal Year Ended December 31, 2023 Part I Item 1. Business, page 7 1.We note your risk factor disclosure on page 12 that you may offer early termination rights as a lease incentive and statements made on your February 22, 2024 earnings call regarding the lease termination associated with the sale of an office property in Tyler, Texas. Please tell us, and in future filings please discuss, the number of your leases that have early termination provisions, the impact to the company from the exercise of such provisions, the number of tenants who have exercised these provisions over the past two years, and the amount of square footage involved. 2.We note your risk factor disclosure on page 10 that you may not be able to verify the credit quality of certain tenants prior to leasing properties to them. Please tell us, and in future Exchange Act reports discuss, how you monitor tenant credit quality and identify any material changes in quality.

September 17, 2024 Page 2 Item 2. Properties, page 32 3.We note from your lease expiration table that 8.7% of your leases will expire by the end of the current fiscal year and approximately 25% will expire over the next four years. In future Exchange Act periodic reports, please discuss the relationship between market rents and expiring rents. In addition, include a comparison of rent on any second-generation leases and renewed leases to prior rents. 4.We note you disclose annualized base rent. To the extent your leases contain material tenant concessions or abatements, in future filings, please disclose your average effective annual rent per square foot and and discuss how tenant concessionsimpact your average annualized rent. 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 Frank Knapp at 202-551-3805 or Wilson Lee at 202-551-3468 if you have questions regarding comments on the financial statements and related matters. Please contact Catherine De Lorenzo at 202-551-3772 or Isabel Rivera at 202-551-3518 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Lewis Kneib

Show Raw Text
September 17, 2024
Javier Bitar
Chief Financial Officer and Treasurer
Peakstone Realty Trust
1520 E. Grand Avenue
El Segundo, CA 90245
Re:Peakstone Realty Trust
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-41686
Dear Javier Bitar:
            We have reviewed your filing and have the following comments.
            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 Fiscal Year Ended December 31, 2023
Part I
Item 1. Business, page 7
1.We note your risk factor disclosure on page 12 that you may offer early termination rights
as a lease incentive and statements made on your February 22, 2024 earnings call
regarding the lease termination associated with the sale of an office property in Tyler,
Texas. Please tell us, and in future filings please discuss, the number of your leases that
have early termination provisions, the impact to the company from the exercise of such
provisions, the number of tenants who have exercised these provisions over the past two
years, and the amount of square footage involved.
2.We note your risk factor disclosure on page 10 that you may not be able to verify the
credit quality of certain tenants prior to leasing properties to them. Please tell us, and in
future Exchange Act reports discuss, how you monitor tenant credit quality and identify
any material changes in quality.

September 17, 2024
Page 2
Item 2. Properties, page 32
3.We note from your lease expiration table that 8.7% of your leases will expire by the end
of the current fiscal year and approximately 25% will expire over the next four years. In
future Exchange Act periodic reports, please discuss the relationship between market rents
and expiring rents. In addition, include a comparison of rent on any second-generation
leases and renewed leases to prior rents.
4.We note you disclose annualized base rent. To the extent your leases contain material
tenant concessions or abatements, in future filings, please disclose your average effective
annual rent per square foot and and discuss how tenant concessionsimpact your average
annualized rent.
            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 Frank Knapp at 202-551-3805 or Wilson Lee at 202-551-3468 if you have
questions regarding comments on the financial statements and related matters. Please contact
Catherine De Lorenzo at 202-551-3772 or Isabel Rivera at 202-551-3518 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Lewis Kneib