SEC Comment Letter 0000000000-23-008180 to Starwood Real Estate Income Trust, Inc. (CIK 0001711929) (SWDR)
Starwood Real Estate Income Trust, Inc. (CIK 0001711929)
Date: July 31, 2023 · CIK: 0001711929 · Accession: 0000000000-23-008180
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-56046
Letter
United States securities and exchange commission logo July 31, 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 July 20, 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 July 6, 2023 letter. 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 your response to our prior comment. Please clarify what is meant by "through December 31, 2022, the Company’s loans secured by real estate have been recorded at par value, which approximates fair value and is also equal to the origination cost," as this contradicts your policy of recording loans secured by real estate at fair value. If you have been utilizing the discounted cash flow method to value your loans secured by real estate (as well as reviewing market yield data, collateral asset performance, local and macro real estate performance, capital market conditions, debt yield and loan-to-value ratios and borrower financial condition and performance), and the value derived from such methods was approximately the same as par/cost, then please clearly state this in your response.
FirstName LastNameChris Lowthert Comapany NameStarwood Real Estate Income Trust, Inc. July 31, 2023 Page 2 FirstName LastName Chris Lowthert Starwood Real Estate Income Trust, Inc. July 31, 2023 Page 2 You may contact William Demarest at 202-551-3432 or Kristi Marrone at 202-551-3429 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Matthew Guttin
Show Raw Text
United States securities and exchange commission logo
July 31, 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 July 20, 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
July 6, 2023 letter.
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 your response to our prior comment. Please clarify what is meant by "through
December 31, 2022, the Company’s loans secured by real estate have been recorded at par
value, which approximates fair value and is also equal to the origination cost," as this
contradicts your policy of recording loans secured by real estate at fair value. If you have
been utilizing the discounted cash flow method to value your loans secured by real estate
(as well as reviewing market yield data, collateral asset performance, local and macro real
estate performance, capital market conditions, debt yield and loan-to-value ratios and
borrower financial condition and performance), and the value derived from such methods
was approximately the same as par/cost, then please clearly state this in your response.
FirstName LastNameChris Lowthert
Comapany NameStarwood Real Estate Income Trust, Inc.
July 31, 2023 Page 2
FirstName LastName
Chris Lowthert
Starwood Real Estate Income Trust, Inc.
July 31, 2023
Page 2
You may contact William Demarest at 202-551-3432 or Kristi Marrone at 202-551-3429
if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Matthew Guttin