SEC Comment Letter 0000000000-24-009613 to NewLake Capital Partners, Inc. (NLCP)
NewLake Capital Partners, Inc.
Date: Aug. 22, 2024 · CIK: 0001854964 · Accession: 0000000000-24-009613
AI Filing Summary & Sentiment
File numbers found in text: 000-56327
Letter
August 22, 2024 Lisa Meyer Chief Financial Officer, Treasurer & Secretary NewLake Capital Partners, Inc. 50 Locust Ave First Floor New Canaan, CT 06840 Re:NewLake Capital Partners, Inc. Form 10-K for the fiscal year ended December 31, 2023 File No. 000-56327 Filed March 11, 2024 Dear Lisa Meyer: We have limited our review of your filing to the financial statements and related disclosures 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 the 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 fiscal year ended December 31, 2023 Notes to Consolidated Financial Statements Note 2 - Basis of Presentation and Summary of Significant Accounting Policies Revenue Recognition, page F-10 We note your disclosure stating that you record rental income, fees and reimbursables for your operating leases on a cash basis due to your tenants limited operating history and the uncertain regulatory environment in the United States relating to the cannabis industry. We further note that the ongoing assessments of collectability should be made on a lease by lease basis, that the passage of time resulted in your existing tenants having a more than limited operating history, and that your disclosure indicates all but one of your tenants has been performing under their lease agreements. In light of the foregoing, please tell us how the Company reassessed the collectability criterion on its operating leases on a lease by lease basis. In providing your response, please tell us how you considered the example in ASC 842-30-55-25, whereby the collectability of lease payments is not 1.
August 22, 2024 Page 2 probable at lease inception and subsequently deemed probable after the tenant has established a rental history. In closing, 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 Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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August 22, 2024
Lisa Meyer
Chief Financial Officer, Treasurer & Secretary
NewLake Capital Partners, Inc.
50 Locust Ave
First Floor
New Canaan, CT 06840
Re:NewLake Capital Partners, Inc.
Form 10-K for the fiscal year ended December 31, 2023
File No. 000-56327
Filed March 11, 2024
Dear Lisa Meyer:
We have limited our review of your filing to the financial statements and related
disclosures 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
the 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 fiscal year ended December 31, 2023
Notes to Consolidated Financial Statements
Note 2 - Basis of Presentation and Summary of Significant Accounting Policies
Revenue Recognition, page F-10
We note your disclosure stating that you record rental income, fees and reimbursables for
your operating leases on a cash basis due to your tenants limited operating history and the
uncertain regulatory environment in the United States relating to the cannabis industry.
We further note that the ongoing assessments of collectability should be made on a lease
by lease basis, that the passage of time resulted in your existing tenants having a more
than limited operating history, and that your disclosure indicates all but one of your
tenants has been performing under their lease agreements. In light of the foregoing, please
tell us how the Company reassessed the collectability criterion on its operating leases on a
lease by lease basis. In providing your response, please tell us how you considered the
example in ASC 842-30-55-25, whereby the collectability of lease payments is not 1.
August 22, 2024
Page 2
probable at lease inception and subsequently deemed probable after the tenant has
established a rental history.
In closing, 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 Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction