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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

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 000-55776

Date
December 31, 2016
Author
/s/ Robert F. Telewicz, Jr.
Form
UPLOAD
Company
MODIV INDUSTRIAL, INC. (MDV, MDV-PA) (CIK 0001645873)

Letter

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.

Show Raw Text
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