SEC Company Response from Blackstone Real Estate Income Trust, Inc. (BSTT) (CIK 0001662972) (BSTT) — Aug 17, 2017
Blackstone Real Estate Income Trust, Inc. (BSTT) (CIK 0001662972)
Date: Aug. 17, 2017 · CIK: 0001662972 · Accession: 0001193125-17-260464
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-213043
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Attention: Coy Garrison, Special Counsel Re: Blackstone Real Estate Income Trust, Inc. Post-Effective Amendment No. 5 to Form S-11 Filed July 13, 2017 File No. 333-213043
Dear Mr. Garrison:
We have been authorized by Blackstone Real Estate Income Trust, Inc., a Maryland corporation (the “Company”) to provide the following response to your oral comments delivered by telephone on July 21, 2017, to Eva Kang of our office regarding the Company’s Post-Effective Amendment No. 5 to the Company’s Registration Statement on Form S-11 (File No. 333-213043) (“Amendment No. 5”), filed with the Securities and Exchange Commission on July 13, 2017. For ease of review, your comments appear in italics with the Company’s responses immediately following.
Historical NAV Per Share
1. Please clarify that the “Accrued Stockholder Servicing Fees” line item is different than the figure provided for accrued stockholder servicing fees under GAAP in the Company’s periodic filings and quantify the amount of stockholder servicing fees accrued under GAAP.
Response:
In response to your comment, the Company will update the footnote with respect to “Accrued Stockholder Servicing Fees” in future filing to clarify the differences between the accrual of stockholder servicing fees for purposes of NAV and pursuant to GAAP, and to quantify the amount of such accrued stockholder servicing fees under GAAP.
Securities and Exchange Commission
August 17, 2017
Incorporation By Reference
2. Please update this section to incorporate by reference the annual proxy statement.
Response:
The Company acknowledges the comment and will update the section in the Company’s next prospectus supplement.
If this is acceptable, we request the Staff to declare Amendment No. 5 effective at the earliest practicable time. Please do not hesitate to call me at (212) 455-3577 with any questions or further comments regarding this submission or if you wish to discuss any of the above responses.
Very truly yours,
/s/ Andrew R. Keller
Show Raw Text
CORRESP 1 filename1.htm CORRESP SIMPSON THACHER & BARTLETT LLP 425 LEXINGTON AVENUE NEW YORK, NY 10017-3954 (212) 455-2000 FACSIMILE (212) 455-2502 DIRECT DIAL NUMBER E-MAIL ADDRESS (212) 455-3577 AKELLER@STBLAW.COM August 17, 2017 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Coy Garrison, Special Counsel Re: Blackstone Real Estate Income Trust, Inc. Post-Effective Amendment No. 5 to Form S-11 Filed July 13, 2017 File No. 333-213043 Dear Mr. Garrison: We have been authorized by Blackstone Real Estate Income Trust, Inc., a Maryland corporation (the “Company”) to provide the following response to your oral comments delivered by telephone on July 21, 2017, to Eva Kang of our office regarding the Company’s Post-Effective Amendment No. 5 to the Company’s Registration Statement on Form S-11 (File No. 333-213043) (“Amendment No. 5”), filed with the Securities and Exchange Commission on July 13, 2017. For ease of review, your comments appear in italics with the Company’s responses immediately following. Historical NAV Per Share 1. Please clarify that the “Accrued Stockholder Servicing Fees” line item is different than the figure provided for accrued stockholder servicing fees under GAAP in the Company’s periodic filings and quantify the amount of stockholder servicing fees accrued under GAAP. Response: In response to your comment, the Company will update the footnote with respect to “Accrued Stockholder Servicing Fees” in future filing to clarify the differences between the accrual of stockholder servicing fees for purposes of NAV and pursuant to GAAP, and to quantify the amount of such accrued stockholder servicing fees under GAAP. Securities and Exchange Commission August 17, 2017 Incorporation By Reference 2. Please update this section to incorporate by reference the annual proxy statement. Response: The Company acknowledges the comment and will update the section in the Company’s next prospectus supplement. If this is acceptable, we request the Staff to declare Amendment No. 5 effective at the earliest practicable time. Please do not hesitate to call me at (212) 455-3577 with any questions or further comments regarding this submission or if you wish to discuss any of the above responses. Very truly yours, /s/ Andrew R. Keller Andrew R. Keller cc: Leon Volchyok