SEC Company Response from Starwood Real Estate Income Trust, Inc. (SWDR) (CIK 0001711929) (SWDR) — Aug 21, 2019
Starwood Real Estate Income Trust, Inc. (SWDR) (CIK 0001711929)
Date: Aug. 21, 2019 · CIK: 0001711929 · Accession: 0001193125-19-225990
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-56046, 333-220997
Referenced dates: August 9, 2019
Letter
Re: Starwood Real Estate Income Trust, Inc.
August 21, 2019
VIA EDGAR
Isaac Esquivel
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
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
Ladies and Gentlemen:
On behalf of Starwood Real Estate Income Trust, Inc. (the “Company”), we hereby file with the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission responses to the comment from the Staff’s comment letter dated August 9, 2019 relating to the above-referenced annual and quarterly filings on Form 10-K and Form 10-Q.
To assist your review, we have retyped the text of the Staff’s comments that the Company is responding to in this letter in italics below.
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.
Response
The Company confirms that it will include the requested information in future periodic filings when material changes in NAV are reported. The requested changes can be found in the Company’s Form 10-Q for the Quarter Ended June 30, 2019 filed August 12, 2019 on page 31. This information is also provided in supplements to the prospectus of the Company, dated April 16, 2019 (as supplemented to date, the “Prospectus” File No. 333-220997) where the transaction price for each class of the Company’s common stock is disclosed.
* * * * * * * *
Please do not hesitate to call me at (203) 422-7775 with any questions or further comments regarding this submission or if you wish to discuss the above response.
Very truly yours,
/s/ Matthew
Guttin
Show Raw Text
CORRESP 1 filename1.htm CORRESP August 21, 2019 VIA EDGAR Isaac Esquivel Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 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 Ladies and Gentlemen: On behalf of Starwood Real Estate Income Trust, Inc. (the “Company”), we hereby file with the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission responses to the comment from the Staff’s comment letter dated August 9, 2019 relating to the above-referenced annual and quarterly filings on Form 10-K and Form 10-Q. To assist your review, we have retyped the text of the Staff’s comments that the Company is responding to in this letter in italics below. 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. Response The Company confirms that it will include the requested information in future periodic filings when material changes in NAV are reported. The requested changes can be found in the Company’s Form 10-Q for the Quarter Ended June 30, 2019 filed August 12, 2019 on page 31. This information is also provided in supplements to the prospectus of the Company, dated April 16, 2019 (as supplemented to date, the “Prospectus” File No. 333-220997) where the transaction price for each class of the Company’s common stock is disclosed. * * * * * * * * Please do not hesitate to call me at (203) 422-7775 with any questions or further comments regarding this submission or if you wish to discuss the above response. Very truly yours, /s/ Matthew Guttin Matthew Guttin cc: Dave Guiteau John P. McCarthy, Jr.