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SEC Company Response from NexPoint Real Estate Finance, Inc. (NREF, NREF-PA) (CIK 0001786248) (NREF) — Aug 23, 2021

NexPoint Real Estate Finance, Inc. (NREF, NREF-PA) (CIK 0001786248)
Date: Aug. 23, 2021 · CIK: 0001786248 · Accession: 0001437749-21-020711

AI Filing Summary & Sentiment

File numbers found in text: 001-39210

Referenced dates: August 19, 2021

Date
August 23, 2021
Author
/s/ Charles T. Haag
Form
CORRESP
Company
NexPoint Real Estate Finance, Inc. (NREF, NREF-PA) (CIK 0001786248)

Letter

nref20210823_corresp.htm

August 23, 2021

BY EDGAR

Jeffrey Lewis

Office of Real Estate and Construction

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Re:

NexPoint Real Estate Finance, Inc.

Form 10-K for the fiscal year ended December 31, 2020

Filed February 25, 2021

Form 10-Q for the quarterly period ended June 30, 2021

Filed August 3, 2021

File No. 001-39210

Ladies and Gentlemen:

On behalf of NexPoint Real Estate Finance, Inc. (the “Company”), we are responding to the comment of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) contained in its letter dated August 19, 2021. For ease of reference, the text of the Staff’s comment is included in bold-face type below, followed by the Company’s response.

Form 10-Q for the quarterly period ended June 30, 2021

Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Core Earnings, page 31

1.

We note your response to comment 1 and continue to believe the measure should be retitled given the adjustments for various unrealized gains (losses) which appear to relate to current operations (e.g. company holding CMBS until maturity). Please revise the title of the measure in future filings to more appropriately reflect its use.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that, further to the Company’s discussion with the Staff on August 13, 2021, the Company will revise the title of the measure in future filings beginning with its Quarterly Report on Form 10-Q for the quarter ended September 30, 2021, and in all subsequent reporting periods.

* * * * * * *

United States Securities and Exchange Commission

August 23, 2021

Page 2 of 2

If you have any questions, please feel free to contact me at 214.453.6494. Thank you for your cooperation and prompt attention to this matter.

Sincerely,
/s/ Charles T. Haag

Show Raw Text
CORRESP
1
filename1.htm

	nref20210823_corresp.htm

August 23, 2021

BY EDGAR

Jeffrey Lewis

Office of Real Estate and Construction

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

			Re:

			NexPoint Real Estate Finance, Inc.

			Form 10-K for the fiscal year ended December 31, 2020

			Filed February 25, 2021

			Form 10-Q for the quarterly period ended June 30, 2021

			Filed August 3, 2021

			File No. 001-39210

Ladies and Gentlemen:

On behalf of NexPoint Real Estate Finance, Inc. (the “Company”), we are responding to the comment of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) contained in its letter dated August 19, 2021. For ease of reference, the text of the Staff’s comment is included in bold-face type below, followed by the Company’s response.

Form 10-Q for the quarterly period ended June 30, 2021

Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Core Earnings, page 31

			1.

			We note your response to comment 1 and continue to believe the measure should be retitled given the adjustments for various unrealized gains (losses) which appear to relate to current operations (e.g. company holding CMBS until maturity). Please revise the title of the measure in future filings to more appropriately reflect its use.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that, further to the Company’s discussion with the Staff on August 13, 2021, the Company will revise the title of the measure in future filings beginning with its Quarterly Report on Form 10-Q for the quarter ended September 30, 2021, and in all subsequent reporting periods.

* * * * * * *

United States Securities and Exchange Commission

August 23, 2021

Page 2 of 2

If you have any questions, please feel free to contact me at 214.453.6494. Thank you for your cooperation and prompt attention to this matter.

			Sincerely,

			/s/ Charles T. Haag

			Charles T. Haag

			cc:

			Brian Mitts, Chief Financial Officer, Executive VP-Finance, Secretary and

			Treasurer, NexPoint Real Estate Finance, Inc.

			Justin S. Reinus, Partner, Winston & Strawn LLP