SEC Comment Letter for Invesco Real Estate Income Trust Inc. (CIK 0001756761) — Dec 7, 2020
Invesco Real Estate Income Trust Inc. (CIK 0001756761)
Date: Dec. 7, 2020 · CIK: 0001756761 · Accession: 0000000000-20-011697
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Letter
United States securities and exchange commission logo December 7, 2020 R. Scott Dennis Chief Executive Officer Invesco Real Estate Income Trust Inc. 1555 Peachtree Street, N.E. Suite 1800 Atlanta, Georgia 30309 Re:Invesco Real Estate Income Trust Inc. Amendment No. 2 to Draft Registration Statement on Form S-11 Submitted November 12, 2020 CIK No. 0001756761 Dear Mr. Dennis: We have reviewed your amended draft registration statement 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 letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment to Draft Registration Statement on Form S-11 Investment Portfolio Medical Office Portfolio, page 110 1.We note your disclosure relating to your September 29, 2020 acquisition of an ownership interest in the MOB Portfolio and that you may acquire up to seven additional MOBs. Please tell us how you determined it was unnecessary to provide financial statements and pro forma financial information related to these acquired or to be acquired properties.
FirstName LastNameR. Scott Dennis Comapany NameInvesco Real Estate Income Trust Inc. December 7, 2020 Page 2 FirstName LastName R. Scott Dennis Invesco Real Estate Income Trust Inc. December 7, 2020 Page 2 You may contact Jorge Bonilla at 202-551-3414 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Please contact Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Aaron C. Hendricson
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United States securities and exchange commission logo
December 7, 2020
R. Scott Dennis
Chief Executive Officer
Invesco Real Estate Income Trust Inc.
1555 Peachtree Street, N.E. Suite 1800
Atlanta, Georgia 30309
Re:Invesco Real Estate Income Trust Inc.
Amendment No. 2 to Draft Registration Statement on Form S-11
Submitted November 12, 2020
CIK No. 0001756761
Dear Mr. Dennis:
We have reviewed your amended draft registration statement 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 letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment to Draft Registration Statement on Form S-11
Investment Portfolio
Medical Office Portfolio, page 110
1.We note your disclosure relating to your September 29, 2020 acquisition of an ownership
interest in the MOB Portfolio and that you may acquire up to seven additional MOBs.
Please tell us how you determined it was unnecessary to provide financial statements and
pro forma financial information related to these acquired or to be acquired properties.
FirstName LastNameR. Scott Dennis
Comapany NameInvesco Real Estate Income Trust Inc.
December 7, 2020 Page 2
FirstName LastName
R. Scott Dennis
Invesco Real Estate Income Trust Inc.
December 7, 2020
Page 2
You may contact Jorge Bonilla at 202-551-3414 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters. Please
contact Ronald (Ron) E. Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Aaron C. Hendricson