SEC Comment Letter for KKR Real Estate Finance Trust Inc. (KREF, KREF-PA) (CIK 0001631596) (KREF) — May 1, 2017
KKR Real Estate Finance Trust Inc. (KREF, KREF-PA) (CIK 0001631596)
Date: May 1, 2017 · CIK: 0001631596 · Accession: 0000000000-17-015111
AI Filing Summary & Sentiment
File numbers found in text: 333-217126
Letter
Mail Stop 3233 May 1, 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. 2 to Registration Statement on Form S-11 Filed April 26, 2017 File No. 333-217126
Dear Mr. Lee :
We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in y our response.
After reviewing any amendment to your registration statement and the information you provide in response to our comment , we may have additional comments. Unless we note otherwise , our references to prior comments are to comments in our April 24, 2017 letter .
Capitalization, page 84
1. Please supplementally tell us how you arrived at the “As Adjusted” cash and cash equivalents, as it appears that the amount may include other adjustments than those described on page 84. Alternatively, cash amounts may be removed from the capitalization table.
Christen E .J. Lee KKR Real Estate Finance Trust Inc. May 1, 2017 Page 2
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 financial 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 May 1, 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. 2 to Registration Statement on Form S-11 Filed April 26, 2017 File No. 333-217126 Dear Mr. Lee : We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment appl ies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in y our response. After reviewing any amendment to your registration statement and the information you provide in response to our comment , we may have additional comments. Unless we note otherwise , our references to prior comments are to comments in our April 24, 2017 letter . Capitalization, page 84 1. Please supplementally tell us how you arrived at the “As Adjusted” cash and cash equivalents, as it appears that the amount may include other adjustments than those described on page 84. Alternatively, cash amounts may be removed from the capitalization table. Christen E .J. Lee KKR Real Estate Finance Trust Inc. May 1, 2017 Page 2 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 financial 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