CORRESP Filing
Claros Mortgage Trust, Inc.
Date: Aug. 11, 2025 · CIK: 0001666291 · Accession: 0001193125-25-178187
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-40993
Letter
10250 Constellation Blvd., Suite 1100
Los Angeles, California 90067
Tel: +1.424.653.5500 Fax: +1.424.653.5501 www.lw.com
FIRM / AFFILIATE OFFICES
Austin
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August 11, 2025
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Washington, D.C. Via EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, DC 20549 Attention: Jeffrey Lewis and Shannon Menjivar
Re: Claros Mortgage Trust, Inc. Form 10-K for the fiscal year ended December 31, 2024 Form 10-Q for the quarterly period ended March 31, 2025 File No. 001-40993 Dear Mr. Lewis and Ms. Menjivar: On behalf of our client, Claros Mortgage Trust, Inc., a Maryland corporation (the “ Company ”), set forth below is the Company’s response to the comment letter, dated August 4, 2025, from the staff of the Division of Corporation Finance (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ SEC ”), relating to the Company’s Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2025 (the “ Form 10- Q ”). For convenience of reference, the text of the Staff’s comment has been reproduced below in bold and italics, followed by the Company’s response thereto. All terms used but not defined herein have the meanings assigned to such terms in the Form 10-Q. Form 10-Q for the quarterly period ended March 31, 2025 Note 15. Segment Reporting, page 29
1. We note your calculation of Distributable Loss for your loan and REO portfolios, as well as your reconciliation to Net loss. Please tell us whether operating expenses represents a significant segment expense determined in accordance with ASC 280-10-50-26A or if it represents “other segment items” in accordance with ASC 280-10-50- 26B. If the amount represents other segment items, please tell us how you complied with the guidance in ASC 280-10-50-26B, including disclosure of a qualitative description of the composition of other segment items.
August 11, 2025 Page 2
Response : The Company acknowledges the Staff’s comment. The Company respectfully advises the Staff that operating expenses for the Company’s real estate owned portfolio represent a significant segment expense determined in accordance with ASC 280-10-50-26A and are regularly provided to the Chief Operating Decision Maker. * * * * If you have any questions or comments with regard to this response or other matters, please call me at (213) 891-8185. For any future written correspondence sent by email, please use the following address: brent.epstein@lw.com.
Sincerely,
/s/ Brent T. Epstein
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CORRESP 1 filename1.htm CORRESP 10250 Constellation Blvd., Suite 1100 Los Angeles, California 90067 Tel: +1.424.653.5500 Fax: +1.424.653.5501 www.lw.com FIRM / AFFILIATE OFFICES Austin Milan Beijing Munich Boston New York Brussels Orange County Chicago Paris Dubai Riyadh August 11, 2025 Düsseldorf San Diego Frankfurt San Francisco Hamburg Seoul Hong Kong Silicon Valley Houston Singapore London Tel Aviv Los Angeles Tokyo Madrid Washington, D.C. Via EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, DC 20549 Attention: Jeffrey Lewis and Shannon Menjivar Re: Claros Mortgage Trust, Inc. Form 10-K for the fiscal year ended December 31, 2024 Form 10-Q for the quarterly period ended March 31, 2025 File No. 001-40993 Dear Mr. Lewis and Ms. Menjivar: On behalf of our client, Claros Mortgage Trust, Inc., a Maryland corporation (the “ Company ”), set forth below is the Company’s response to the comment letter, dated August 4, 2025, from the staff of the Division of Corporation Finance (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ SEC ”), relating to the Company’s Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2025 (the “ Form 10- Q ”). For convenience of reference, the text of the Staff’s comment has been reproduced below in bold and italics, followed by the Company’s response thereto. All terms used but not defined herein have the meanings assigned to such terms in the Form 10-Q. Form 10-Q for the quarterly period ended March 31, 2025 Note 15. Segment Reporting, page 29 1. We note your calculation of Distributable Loss for your loan and REO portfolios, as well as your reconciliation to Net loss. Please tell us whether operating expenses represents a significant segment expense determined in accordance with ASC 280-10-50-26A or if it represents “other segment items” in accordance with ASC 280-10-50- 26B. If the amount represents other segment items, please tell us how you complied with the guidance in ASC 280-10-50-26B, including disclosure of a qualitative description of the composition of other segment items. August 11, 2025 Page 2 Response : The Company acknowledges the Staff’s comment. The Company respectfully advises the Staff that operating expenses for the Company’s real estate owned portfolio represent a significant segment expense determined in accordance with ASC 280-10-50-26A and are regularly provided to the Chief Operating Decision Maker. * * * * If you have any questions or comments with regard to this response or other matters, please call me at (213) 891-8185. For any future written correspondence sent by email, please use the following address: brent.epstein@lw.com. Sincerely, /s/ Brent T. Epstein Brent T. Epstein of LATHAM & WATKINS LLP Cc: J. Michael McGillis, Claros Mortgage Trust, Inc. J.D. Siegel, Claros Mortgage Trust, Inc. Devon MacLaughlin, Latham & Watkins LLP 2