SEC Comment Letter for MODIV INDUSTRIAL, INC. (MDV, MDV-PA) (CIK 0001645873) (MDV) — Dec 22, 2017
MODIV INDUSTRIAL, INC. (MDV, MDV-PA) (CIK 0001645873)
Date: Dec. 22, 2017 · CIK: 0001645873 · Accession: 0000000000-17-044979
AI Filing Summary & Sentiment
File numbers found in text: 000-55776
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Mail Stop 3233
December 22 , 2017
Via E -mail
Jean Ho
Chief Financial Officer
RW Holdings NNN REIT
3090 Bristol Street , Suite 550
Costa Mesa, CA 92626
Re: RW Holdings NNN REIT
Form 10-K for the fiscal year ended December 31, 201 6
Filed April 3 , 2017
File No. 000-55776
Dear Ms. Ho:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. 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 comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. I f 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.
Form 10 -K for the year ended December 31, 2016
General
1. Please tell us how you considered the need to provide audited financial statements of
tenants that occupy properties purchased during 2017 or 2016, or audited financial
statements of the operations of those properties. Please provide us with your significan ce
test for all properties acquired in 2016 and 2017 in your response. Refer to Rule 8 -06 of
Regulation S -X.
Jean Ho
RW Holdings NNN REIT
December 22 , 2017
Page 2
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.
You may contact Eric McPhee at (202) 551 -3693 or the undersigned at (202) 551 -3438
with any questions.
Sincerely,
/s/ Robert F. Telewicz, Jr.
Robert F. Telewicz , Jr.
Branch Chief
Off ice of Real Estate and
Commodities