SEC Comment Letter for Starwood Real Estate Income Trust, Inc. (SWDR) (CIK 0001711929) (SWDR) — Aug 12, 2019
Starwood Real Estate Income Trust, Inc. (SWDR) (CIK 0001711929)
Date: Aug. 12, 2019 · CIK: 0001711929 · Accession: 0000000000-19-012287
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-56046, 333-220997
Letter
August 9, 2019 Dave Guiteau Chief Financial Officer Starwood Real Estate Income Trust, Inc. 1601 Washington Avenue Suite 800 Miami Beach, FL 33139 Re:Starwood Real Estate Income Trust, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 28, 2019 File No. 333-220997 Form 10-Q for the Quarter Ended March 31, 2019 Filed May 14, 2019 File No. 000-56046 Dear Mr. Guiteau: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-Q for the Quarter Ended March 31, 2019 Net Asset Value, page 25 1.We note that you have acquired real estate investments that are material to your calculation of NAV. Please confirm to us that you will include a description of your valuation guidelines for these investments in future periodic filings when material changes in NAV are reported. The disclosure should include primary valuation method(s) and key assumptions used to determine the fair value of the investments. In closing, 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
FirstName LastNameDave Guiteau Comapany NameStarwood Real Estate Income Trust, Inc. August 9, 2019 Page 2 FirstName LastName Dave Guiteau Starwood Real Estate Income Trust, Inc. August 9, 2019 Page 2 absence of action by the staff. You may contact Isaac Esquivel at (202) 551-3395 or Kristi Marrone at (202) 551-3429 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate and Commodities
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August 9, 2019
Dave Guiteau
Chief Financial Officer
Starwood Real Estate Income Trust, Inc.
1601 Washington Avenue
Suite 800
Miami Beach, FL 33139
Re:Starwood Real Estate Income Trust, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed March 28, 2019
File No. 333-220997
Form 10-Q for the Quarter Ended March 31, 2019
Filed May 14, 2019
File No. 000-56046
Dear Mr. Guiteau:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-Q for the Quarter Ended March 31, 2019
Net Asset Value, page 25
1.We note that you have acquired real estate investments that are material to your
calculation of NAV. Please confirm to us that you will include a description of your
valuation guidelines for these investments in future periodic filings when material changes
in NAV are reported. The disclosure should include primary valuation method(s) and key
assumptions used to determine the fair value of the investments.
In closing, 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
FirstName LastNameDave Guiteau
Comapany NameStarwood Real Estate Income Trust, Inc.
August 9, 2019 Page 2
FirstName LastName
Dave Guiteau
Starwood Real Estate Income Trust, Inc.
August 9, 2019
Page 2
absence of action by the staff.
You may contact Isaac Esquivel at (202) 551-3395 or Kristi Marrone at (202) 551-3429
with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities