SEC Comment Letter 0000000000-24-012245 to ExchangeRight Income Fund (CIK 0001771514)
ExchangeRight Income Fund (CIK 0001771514)
Date: Nov. 4, 2024 · CIK: 0001771514 · Accession: 0000000000-24-012245
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-56543
Letter
November 4, 2024 David Van Steenis Chief Financial Officer ExchangeRight Income Fund 1055 E. Colorado Blvd Suite 310 Pasadena, California 91106 Re:ExchangeRight Income Fund Form 10-K for the year ended December 31, 2023 Filed on April 11, 2024 File No. 000-56543 Dear David Van Steenis: 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 the year ended December 31, 2023 Note 2. Summary of Significant Accounting Policies Principles of Consolidation, page F-9 1.Your consolidated financial statements include the accounts of various legal entities and your significant accounting policies indicates that you consolidate variable interest entities when you are the primary beneficiary. Please expand your disclosures to clarify whether any of the entities that are consolidated are considered variable interest entities under ASC 810-10-15-14. If so, please provide the disclosures required by ASC 810-10-50-2AA and tell us how you considered the presentation guidance under ASC 810-10-45-25. 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 Shannon Menjivar at 202-551- 3856 if you have questions regarding comments on the financial statements and related
November 4, 2024 Page 2 matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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November 4, 2024
David Van Steenis
Chief Financial Officer
ExchangeRight Income Fund
1055 E. Colorado Blvd Suite 310
Pasadena, California 91106
Re:ExchangeRight Income Fund
Form 10-K for the year ended December 31, 2023
Filed on April 11, 2024
File No. 000-56543
Dear David Van Steenis:
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 the year ended December 31, 2023
Note 2. Summary of Significant Accounting Policies
Principles of Consolidation, page F-9
1.Your consolidated financial statements include the accounts of various legal entities
and your significant accounting policies indicates that you consolidate variable
interest entities when you are the primary beneficiary. Please expand your disclosures
to clarify whether any of the entities that are consolidated are considered variable
interest entities under ASC 810-10-15-14. If so, please provide the disclosures
required by ASC 810-10-50-2AA and tell us how you considered the presentation
guidance under ASC 810-10-45-25.
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 Shannon Menjivar at 202-551-
3856 if you have questions regarding comments on the financial statements and related
November 4, 2024
Page 2
matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction