SEC Comment Letter 0000000000-23-001357 to PROCACCIANTI HOTEL REIT, INC. (CIK 0001692345) (PRXA)
PROCACCIANTI HOTEL REIT, INC. (CIK 0001692345)
Date: Feb. 9, 2023 · CIK: 0001692345 · Accession: 0000000000-23-001357
AI Filing Summary & Sentiment
File numbers found in text: 000-56272
Letter
United States securities and exchange commission logo February 9, 2023 Gregory Vickowski Chief Financial Officer Procaccianti Hotel REIT, Inc. 1140 Reservoir Avenue Cranston, RI 02920-6320 Re:Procaccianti Hotel REIT, Inc. Form 10-K for fiscal year ended December 31, 2021 Form 8-K filed June 27, 2022 Response dated January 25, 2023 File Nos. 000-56272 Dear Gregory Vickowski: We have reviewed your January 25, 2023 response to our comment letter and have the following comment. In our comment, 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. If 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. Unless we note otherwise, our references to prior comments are to comments in our December 20, 2022 letter. Form 8-K filed June 27, 2022 Item 8.01 Other Events Determination of Estimated Per Share NAVs, page 1 1.We note your response to prior comment 1. In addition to describing the impact of the liquidation preferences on K Shares, K-I Shares and K-T Shares and subordination of fees payable to the Company’s advisor on your Estimated Per Share NAV calculation, please further enhance your disclosure by providing quantitative information necessary to clearly understand your Estimated Per Share NAV calculation. Please provide us with your Estimated Per Share NAV calculation for each class as of March 31, 2022 in your response.
FirstName LastNameGregory Vickowski Comapany NameProcaccianti Hotel REIT, Inc. February 9, 2023 Page 2 FirstName LastName Gregory Vickowski Procaccianti Hotel REIT, Inc. February 9, 2023 Page 2 You may contact William Demarest at 202-551-3432 or Isaac Esquivel at 202-551-3395 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Ron Hadar
Show Raw Text
United States securities and exchange commission logo
February 9, 2023
Gregory Vickowski
Chief Financial Officer
Procaccianti Hotel REIT, Inc.
1140 Reservoir Avenue
Cranston, RI 02920-6320
Re:Procaccianti Hotel REIT, Inc.
Form 10-K for fiscal year ended December 31, 2021
Form 8-K filed June 27, 2022
Response dated January 25, 2023
File Nos. 000-56272
Dear Gregory Vickowski:
We have reviewed your January 25, 2023 response to our comment letter and have the
following comment. In our comment, 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. If 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. Unless we note otherwise, our references to prior comments are to comments in our
December 20, 2022 letter.
Form 8-K filed June 27, 2022
Item 8.01 Other Events
Determination of Estimated Per Share NAVs, page 1
1.We note your response to prior comment 1. In addition to describing the impact of the
liquidation preferences on K Shares, K-I Shares and K-T Shares and subordination of fees
payable to the Company’s advisor on your Estimated Per Share NAV calculation,
please further enhance your disclosure by providing quantitative information necessary to
clearly understand your Estimated Per Share NAV calculation. Please provide us with
your Estimated Per Share NAV calculation for each class as of March 31, 2022 in your
response.
FirstName LastNameGregory Vickowski
Comapany NameProcaccianti Hotel REIT, Inc.
February 9, 2023 Page 2
FirstName LastName
Gregory Vickowski
Procaccianti Hotel REIT, Inc.
February 9, 2023
Page 2
You may contact William Demarest at 202-551-3432 or Isaac Esquivel at 202-551-3395
if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Ron Hadar