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UPLOAD Filing

Blackstone Real Estate Income Trust, Inc.
Date: June 13, 2025 · CIK: 0001662972 · Accession: 0000000000-25-006245

Financial Reporting Regulatory Compliance Revenue Recognition

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File numbers found in text: 000-55931

Date
June 13, 2025
Author
Division of
Form
UPLOAD
Company
Blackstone Real Estate Income Trust, Inc.

Letter

Re: Blackstone Real Estate Income Trust, Inc. Form 10-K for the fiscal year ended December 31, 2024 File No. 000-55931 Dear Anthony F. Marone, Jr.:

June 13, 2025

Anthony F. Marone, Jr. Chief Financial Officer and Treasurer Blackstone Real Estate Income Trust, Inc. 345 Park Avenue New York, NY 10154

We have limited our review of your filing to the financial statements and related disclosures 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, 2024 Item 5. Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities Funds from Operations, Adjusted Funds from Operations and Funds Available for Distribution, page 105

1. We note your adjustment of $154,536,000 labeled Other to arrive at AFFO attributable to BREIT stockholders and to arrive at AFFO attributable to BREIT stockholders and OP unitholders. Please tell us and enhance your disclosure to clarify the nature of the items in this adjustment. Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Investment Portfolio, page 112

2. We note your presentation of gross asset value in your tabular disclosure on page 113 and your footnote (6) to the table. It appears this measure includes your allocable June 13, 2025 Page 2

share of the fair value of real estate investments held by unconsolidated entities. Please advise, or revise to explicitly clarify what is presented within this measure. 3. We note your presentation of segment revenue in your tabular disclosure on page 113. We further note your footnote (7) to the table indicates this measure includes your allocable share of revenues generated by unconsolidated entities. It appears such measure may be a non-GAAP measure. Please tell how you determined it was unnecessary to include the disclosures required by Item 10(e) of Regulation S-K, or revise to include such disclosures and provide us an example of your proposed disclosures. In your response, please also address your consideration of whether the label "Segment Revenues" is the same as, or confusingly similar to, titles or descriptions used for GAAP financial measures, or revise to relabel the column and provide us with your proposed label. Results of Operations Same Property NOI, page 125

4. We note you have excluded non-core property expenses to arrive at NOI attributable to BREIT stockholders. Please address the following: Please tell us and revise your filing to clarify the nature of these expenses. Tell us and revise your filing to clarify how you determined the exclusion of these expenses is useful to investors. Please clarify for us if these expenses are normal, recurring, cash operating expenses necessary to operate your business. Please refer to Item 10(e) of Regulation S-K and Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. In closing, 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 Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Real
Estate & Construction

Show Raw Text
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<TEXT>
 June 13, 2025

Anthony F. Marone, Jr.
Chief Financial Officer and Treasurer
Blackstone Real Estate Income Trust, Inc.
345 Park Avenue
New York, NY 10154

 Re: Blackstone Real Estate Income Trust, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 File No. 000-55931
Dear Anthony F. Marone, Jr.:

 We have limited our review of your filing to the financial statements
and related
disclosures 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, 2024
Item 5. Market for Registrant's Common Equity, Related Stockholder Matters and
Issuer
Purchases of Equity Securities
Funds from Operations, Adjusted Funds from Operations and Funds Available for
Distribution, page 105

1. We note your adjustment of $154,536,000 labeled Other to arrive at AFFO
 attributable to BREIT stockholders and to arrive at AFFO attributable to
BREIT
 stockholders and OP unitholders. Please tell us and enhance your
disclosure to clarify
 the nature of the items in this adjustment.
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Investment Portfolio, page 112

2. We note your presentation of gross asset value in your tabular
disclosure on page 113
 and your footnote (6) to the table. It appears this measure includes
your allocable
 June 13, 2025
Page 2

 share of the fair value of real estate investments held by
unconsolidated entities.
 Please advise, or revise to explicitly clarify what is presented within
this measure.
3. We note your presentation of segment revenue in your tabular disclosure
on page 113.
 We further note your footnote (7) to the table indicates this measure
includes your
 allocable share of revenues generated by unconsolidated entities. It
appears such
 measure may be a non-GAAP measure. Please tell how you determined it was
 unnecessary to include the disclosures required by Item 10(e) of
Regulation S-K, or
 revise to include such disclosures and provide us an example of your
proposed
 disclosures. In your response, please also address your consideration of
whether the
 label "Segment Revenues" is the same as, or confusingly similar to,
titles or
 descriptions used for GAAP financial measures, or revise to relabel the
column and
 provide us with your proposed label.
Results of Operations
Same Property NOI, page 125

4. We note you have excluded non-core property expenses to arrive at NOI
attributable
 to BREIT stockholders. Please address the following:
 Please tell us and revise your filing to clarify the nature of these
expenses.
 Tell us and revise your filing to clarify how you determined the
exclusion of these
 expenses is useful to investors.
 Please clarify for us if these expenses are normal, recurring, cash
operating
 expenses necessary to operate your business.
 Please refer to Item 10(e) of Regulation S-K and Question 100.01 of the
Non-GAAP
 Financial Measures Compliance and Disclosure Interpretations.
 In closing, 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 Eric McPhee at 202-551-3693 or Jennifer Monick at
202-551-3295
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
</TEXT>
</DOCUMENT>