SEC Comment Letter 0000000000-23-012011 to VINEBROOK HOMES TRUST, INC. (CIK 0001755755)
VINEBROOK HOMES TRUST, INC. (CIK 0001755755)
Date: Nov. 2, 2023 · CIK: 0001755755 · Accession: 0000000000-23-012011
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File numbers found in text: 000-56274
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United States securities and exchange commission logo
November 2, 2023
Brian Mitts
President and Chief Financial Officer
Vinebrook Homes Trust, Inc.
300 Crescent Court, Suite 700
Dallas, TX 75201
Re:Vinebrook Homes Trust, Inc.
Form 10-K for the fiscal year ended December 31, 2021
From 10-K for the fiscal year ended December 31, 2022
Response dated October 4, 2023
File Nos. 000-56274
Dear Brian Mitts:
We have reviewed your October 4, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our September 21, 2023
letter.
From 10-K for the fiscal year ended December 31, 2022
FFO, Core FFO and AFFO, page 87
1.We note from your response to prior comment 3 that FFO, Core FFO and AFFO
were only presented for your Vinebrook reportable segment for comparison purposes
since the investment in NexPoint Homes occurred during fiscal year 2022. Please confirm
if you plan on presenting these non-GAAP measures on a consolidated basis in future
filings where they are reconciled from consolidated net income (loss) attributable to
common stockholders.
FirstName LastNameBrian Mitts
Comapany NameVinebrook Homes Trust, Inc.
November 2, 2023 Page 2
FirstName LastName
Brian Mitts
Vinebrook Homes Trust, Inc.
November 2, 2023
Page 2
Please contact Jeffrey Lewis at 202-551-6216 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