SEC Comment Letter for KKR Real Estate Finance Trust Inc. (KREF, KREF-PA) (CIK 0001631596) (KREF) — Apr 24, 2017
KKR Real Estate Finance Trust Inc. (KREF, KREF-PA) (CIK 0001631596)
Date: April 24, 2017 · CIK: 0001631596 · Accession: 0000000000-17-014077
AI Filing Summary & Sentiment
File numbers found in text: 333-217126
Letter
Mail Stop 3233 April 24, 2017 Via E -Mail Christen E.J. Lee Co-Chief Executive Officer and Co -President KKR Real Estate Finance Manager LLC 9 West 57th Street New York, New York 10019
Re: KKR Real Estate Finance Trust Inc. Amendment No. 1 to Registration Statement on Form S-11 Filed April 13, 2017 File No. 333-217126
Dear Mr. Lee :
We have reviewed your amended registration statement and have the following comments . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments app ly to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise , our references to prior comments are to comments in our April 5, 2017 letter .
Prospectus Summary
Our Target Assets, page 12
1. We note your disclosure that you include within senior loans “ junior participations in our originated senior loans for which we have syndicated the senior participations to other investors and retained the junior participations for our portfolio, typically structured as mezzanine loans. ” Please tell us why it is appropriat e to categorize junior participations structured as mezzanine loans within senior loans.
Christen E.J. Lee KKR Real Estate Finance Trust Inc. April 24, 2017 Page 2
Note 10. Fair Value of Financial Instruments
Valuation Methodologies, page F -40
2. We note your response to comment 13. Please expand your disclosure relating to the valuation of commercial mortgage loans and preferred equity investments to clarify that, in the event that management’s estimate of fair value differs from the opinion of fair value provided by the independent valuation firm, you will ultimately rely solely upon the valuation prepared by the investment personnel of the Manager.
You may contact Bill Demarest, Staff Accountant, at (202) 551 -3432 or Kristi Marrone, Staff Accountant, at (202) 551 -3429 if you have questions regarding comments on the financ ial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202) 551 -8625 or me at (202) 551 -3758 with any other questions.
Sincerely,
/s/ Sandra B, Hunter
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Mail Stop 3233 April 24, 2017 Via E -Mail Christen E.J. Lee Co-Chief Executive Officer and Co -President KKR Real Estate Finance Manager LLC 9 West 57th Street New York, New York 10019 Re: KKR Real Estate Finance Trust Inc. Amendment No. 1 to Registration Statement on Form S-11 Filed April 13, 2017 File No. 333-217126 Dear Mr. Lee : We have reviewed your amended registration statement and have the following comments . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments app ly to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise , our references to prior comments are to comments in our April 5, 2017 letter . Prospectus Summary Our Target Assets, page 12 1. We note your disclosure that you include within senior loans “ junior participations in our originated senior loans for which we have syndicated the senior participations to other investors and retained the junior participations for our portfolio, typically structured as mezzanine loans. ” Please tell us why it is appropriat e to categorize junior participations structured as mezzanine loans within senior loans. Christen E.J. Lee KKR Real Estate Finance Trust Inc. April 24, 2017 Page 2 Note 10. Fair Value of Financial Instruments Valuation Methodologies, page F -40 2. We note your response to comment 13. Please expand your disclosure relating to the valuation of commercial mortgage loans and preferred equity investments to clarify that, in the event that management’s estimate of fair value differs from the opinion of fair value provided by the independent valuation firm, you will ultimately rely solely upon the valuation prepared by the investment personnel of the Manager. You may contact Bill Demarest, Staff Accountant, at (202) 551 -3432 or Kristi Marrone, Staff Accountant, at (202) 551 -3429 if you have questions regarding comments on the financ ial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202) 551 -8625 or me at (202) 551 -3758 with any other questions. Sincerely, /s/ Sandra B, Hunter Sandra B. Hunter Staff Attorney Office of Real Estate and Commodities cc: Joseph H. Kaufman, Esq. Simpson Thacher & Bartlett LLP Via E -mail