SEC Comment Letter for Granite Point Mortgage Trust Inc. (GPMT, GPMT-PA) (CIK 0001703644) (GPMT) — Jun 19, 2017
Granite Point Mortgage Trust Inc. (GPMT, GPMT-PA) (CIK 0001703644)
Date: June 19, 2017 · CIK: 0001703644 · Accession: 0000000000-17-021321
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-218197
Letter
Mailstop 3233 June 19 , 2017 Via E -mail John A. Taylor President and Chief Executive Officer Granite Point Mortgage Trust Inc. 590 Madison Avenue 36th Floor New York, NY 10022
Re: Granite Point Mortgage Trust, Inc. Amendments No. 1 and 2 to Registration Statement on Form S-11 Filed June 15 , 2017 File No. 333-218197
Dear Mr. Taylor :
We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comm ent applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in y our response.
After reviewing any amendment to your registration statement and the information you provide in response to this comment , we may have additional comments.
Exhibit 5.1, Legal Opinion
1. Please refer to assumption (g) on page 3 of the opinio n in which counsel assumes that prior to the issuance of the shares, your charter will be filed with and accepted by the State Department of Assessments and Taxation of Maryland. Since the legal opinion opines that the company is legally incorporated, has sufficient authorized shares and has taken all necessary corporate actions, it appears that this assumption is inappropriate. See our Staff Legal Bulletin No. 19. Please have counsel revise its opi nion to remove this assumption or tell us why you believe it is appropriate.
John A. Taylor Granite Point Mortgage Trust Inc. June 19, 2017 Page 2
You may contact Jeffery Lewis, Staff Accountant , at (202) 551 -6216 or Wilson Lee, Staff Accountant, at (202) 551 -3468 if you have questions regarding comments on the financial statements and related matters. Please contact Sandra B. Hunter , Senior Counsel, at (202) 551 - 3758 or me at (202) 551 -3655 with any other questions.
Sincerely,
/s/ Sonia Gupta Barros
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Mailstop 3233 June 19 , 2017 Via E -mail John A. Taylor President and Chief Executive Officer Granite Point Mortgage Trust Inc. 590 Madison Avenue 36th Floor New York, NY 10022 Re: Granite Point Mortgage Trust, Inc. Amendments No. 1 and 2 to Registration Statement on Form S-11 Filed June 15 , 2017 File No. 333-218197 Dear Mr. Taylor : We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comm ent applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in y our response. After reviewing any amendment to your registration statement and the information you provide in response to this comment , we may have additional comments. Exhibit 5.1, Legal Opinion 1. Please refer to assumption (g) on page 3 of the opinio n in which counsel assumes that prior to the issuance of the shares, your charter will be filed with and accepted by the State Department of Assessments and Taxation of Maryland. Since the legal opinion opines that the company is legally incorporated, has sufficient authorized shares and has taken all necessary corporate actions, it appears that this assumption is inappropriate. See our Staff Legal Bulletin No. 19. Please have counsel revise its opi nion to remove this assumption or tell us why you believe it is appropriate. John A. Taylor Granite Point Mortgage Trust Inc. June 19, 2017 Page 2 You may contact Jeffery Lewis, Staff Accountant , at (202) 551 -6216 or Wilson Lee, Staff Accountant, at (202) 551 -3468 if you have questions regarding comments on the financial statements and related matters. Please contact Sandra B. Hunter , Senior Counsel, at (202) 551 - 3758 or me at (202) 551 -3655 with any other questions. Sincerely, /s/ Sonia Gupta Barros Sonia Gupta Barros Assistant Director Office of Real Estate and Commodities cc: Karen A. Dempsey Orrick, Herrington & Sutcliffe LLP Via E -mail