UPLOAD Filing
BrightSpire Capital, Inc.
Date: July 18, 2025 · CIK: 0001717547 · Accession: 0000000000-25-007614
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38377
Letter
Re: BrightSpire Capital, Inc. Form10-K for the year ended December 31, 2024 File No. 001-38377 Dear Frank V. Saracino:
July 18, 2025
Frank V. Saracino Chief Financial Officer BrightSpire Capital, Inc. 590 Madison Avenue, 33rd Floor New York, NY 10022
We have reviewed your filing and have the following comment.
Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for year ended December 31, 2024 Non-GAAP Supplemental Financial Measures Undepreciated Book Value Per Share, page 60
1. We note your presentation of undepreciated book value and undepreciated book value per share as non-GAAP financial measures. In regards to your presentation please address the following Revise your disclosure regarding the definition of undepreciated book value as it does not appear to address all the items that are being adjusted from the most directly comparable GAAP measure, which appears to be stockholders equity excluding noncontrolling interests in investment entities. Specifically, your definition does not appear to discuss non-GAAP impairment of real estate as an adjustment; and Expand your disclosure to indicate that the non-GAAP impairment adjustment is itself a non-GAAP financial measure, provide a reconciliation to its most directly comparable GAAP measure and expand your disclosure to discuss the usefulness of such measure. Refer to Item 10(e) of Regulation S-K. July 18, 2025 Page 2
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.
Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at 202-551-3395 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of
Corporation Finance
Office of Real Estate
& Construction
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> July 18, 2025 Frank V. Saracino Chief Financial Officer BrightSpire Capital, Inc. 590 Madison Avenue, 33rd Floor New York, NY 10022 Re: BrightSpire Capital, Inc. Form10-K for the year ended December 31, 2024 File No. 001-38377 Dear Frank V. Saracino: We have reviewed your filing and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for year ended December 31, 2024 Non-GAAP Supplemental Financial Measures Undepreciated Book Value Per Share, page 60 1. We note your presentation of undepreciated book value and undepreciated book value per share as non-GAAP financial measures. In regards to your presentation please address the following Revise your disclosure regarding the definition of undepreciated book value as it does not appear to address all the items that are being adjusted from the most directly comparable GAAP measure, which appears to be stockholders equity excluding noncontrolling interests in investment entities. Specifically, your definition does not appear to discuss non-GAAP impairment of real estate as an adjustment; and Expand your disclosure to indicate that the non-GAAP impairment adjustment is itself a non-GAAP financial measure, provide a reconciliation to its most directly comparable GAAP measure and expand your disclosure to discuss the usefulness of such measure. Refer to Item 10(e) of Regulation S-K. July 18, 2025 Page 2 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. Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at 202-551-3395 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction </TEXT> </DOCUMENT>