SEC Comment Letter for Granite Point Mortgage Trust Inc. (GPMT, GPMT-PA) (CIK 0001703644) (GPMT) — Jul 26, 2018
Granite Point Mortgage Trust Inc. (GPMT, GPMT-PA) (CIK 0001703644)
Date: July 26, 2018 · CIK: 0001703644 · Accession: 0000000000-18-023023
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-226128
Letter
Mail Stop 3233 July 26, 2018 Via E -mail John A. Taylor President, Chief Executive Officer and Director Granite Point Mortgage Trust Inc. 590 Madison Avenue 38th Floor New York, NY 10022
Re: Granite Point Mortgage Trust Inc. Registration Statement on Form S-3 Filed July 11, 2018 File No. 333-226128
Dear Mr. Taylor :
We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our com ments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, w e may have additional comments.
General
1. We note that your Contribution Agreement filed as Exhibit 2.1 contains a mandatory arbitration provision. Please clarify whether the mandatory arbitration provision applies to claims under the federal securities laws.
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.
John A. Taylor Granite Point Mortgage Trust Inc. July 26, 2018 Page 2
Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
Please contact Joshua Lobert, Staff Attorney, at (202) 551 -7150 or me at (202) 551 -3391 with any other q uestions.
Sincerely,
/s/ Erin E. Martin
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Mail Stop 3233 July 26, 2018 Via E -mail John A. Taylor President, Chief Executive Officer and Director Granite Point Mortgage Trust Inc. 590 Madison Avenue 38th Floor New York, NY 10022 Re: Granite Point Mortgage Trust Inc. Registration Statement on Form S-3 Filed July 11, 2018 File No. 333-226128 Dear Mr. Taylor : We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our com ments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, w e may have additional comments. General 1. We note that your Contribution Agreement filed as Exhibit 2.1 contains a mandatory arbitration provision. Please clarify whether the mandatory arbitration provision applies to claims under the federal securities laws. 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. John A. Taylor Granite Point Mortgage Trust Inc. July 26, 2018 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Joshua Lobert, Staff Attorney, at (202) 551 -7150 or me at (202) 551 -3391 with any other q uestions. Sincerely, /s/ Erin E. Martin Erin E. Martin Legal Branch Chief Office of Real Estate and Commodities cc: Bryan J. Pitko Stinson Leonard Street LLP