SEC Comment Letter 0000000000-23-007209 to Starwood Real Estate Income Trust, Inc. (CIK 0001711929) (SWDR)
Starwood Real Estate Income Trust, Inc. (CIK 0001711929)
Date: July 6, 2023 · CIK: 0001711929 · Accession: 0000000000-23-007209
AI Filing Summary & Sentiment
File numbers found in text: 000-56046
Letter
United States securities and exchange commission logo July 6, 2023 Chris Lowthert Chief Financial Officer Starwood Real Estate Income Trust, Inc. 2340 Collins Avenue Miami Beach, FL 33139 Re:Starwood Real Estate Income Trust, Inc. Form 10-K for the year ended December 31, 2022 Filed March 17, 2023 File No. 000-56046 Dear Chris Lowthert: We have reviewed your filing 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-K for the year ended December 31, 2022 Note 2. Summary of Significant Accounting Policies Fair Value Measurements, page 112 1.We note that following the initial measurement of loans secured by real estate, the Company will determine fair value by utilizing or reviewing market yield data, discounted cash flow modeling, collateral asset performance, local or macro real estate performance, capital market conditions, debt yield or loan-to-value ratios, and borrower financial condition and performance. Given this policy, please tell us why the level 3 investments in real estate debt have been valued at cost, as adjusted for changes in foreign currency. 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. You may contact William Demarest at 202-551-3432 or Kristi Marrone at 202-551-3429
FirstName LastNameChris Lowthert Comapany NameStarwood Real Estate Income Trust, Inc. July 6, 2023 Page 2 FirstName LastName Chris Lowthert Starwood Real Estate Income Trust, Inc. July 6, 2023 Page 2 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Matthew Guttin
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United States securities and exchange commission logo
July 6, 2023
Chris Lowthert
Chief Financial Officer
Starwood Real Estate Income Trust, Inc.
2340 Collins Avenue
Miami Beach, FL 33139
Re:Starwood Real Estate Income Trust, Inc.
Form 10-K for the year ended December 31, 2022
Filed March 17, 2023
File No. 000-56046
Dear Chris Lowthert:
We have reviewed your filing 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-K for the year ended December 31, 2022
Note 2. Summary of Significant Accounting Policies
Fair Value Measurements, page 112
1.We note that following the initial measurement of loans secured by real estate, the
Company will determine fair value by utilizing or reviewing market yield data, discounted
cash flow modeling, collateral asset performance, local or macro real estate performance,
capital market conditions, debt yield or loan-to-value ratios, and borrower financial
condition and performance. Given this policy, please tell us why the level 3 investments
in real estate debt have been valued at cost, as adjusted for changes in foreign currency.
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.
You may contact William Demarest at 202-551-3432 or Kristi Marrone at 202-551-3429
FirstName LastNameChris Lowthert
Comapany NameStarwood Real Estate Income Trust, Inc.
July 6, 2023 Page 2
FirstName LastName
Chris Lowthert
Starwood Real Estate Income Trust, Inc.
July 6, 2023
Page 2
if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Matthew Guttin