SEC Comment Letter 0000000000-24-008756 to Orion Office REIT Inc. (ONL) (CIK 0001873923) (ONL)
Orion Office REIT Inc. (ONL) (CIK 0001873923)
Date: Aug. 1, 2024 · CIK: 0001873923 · Accession: 0000000000-24-008756
AI Filing Summary & Sentiment
File numbers found in text: 001-40873
Letter
August 1, 2024 Gavin B. Brandon Chief Financial Officer Orion Office REIT Inc. 2398 E. Camelback Road, Suite 1060 Phoenix, AZ 85016 Re:Orion Office REIT Inc. Form 10-K for the Fiscal Year ended December 31, 2023 Response dated July 19, 2024 File No. 001-40873 Dear Gavin B. Brandon: We have reviewed your July 19, 2024 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 a comment in our July 12, 2024 letter. Form 10-K for the year ended December 31, 2023 Item 2. Properties, page 25 1.We acknowledge your response to prior comment 1. Please tell us, and in future filings, please disclose, whether the Class B and Class C properties are concentrated either geographically or by building type ( e.g., traditional office). Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Please contact Kibum Park at 202-551-6836 or Dorrie Yale at 202-551-8776 with any other questions. Sincerely, Division of Corporation Finance
August 1, 2024 Page 2 Office of Real Estate & Construction
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August 1, 2024
Gavin B. Brandon
Chief Financial Officer
Orion Office REIT Inc.
2398 E. Camelback Road, Suite 1060
Phoenix, AZ 85016
Re:Orion Office REIT Inc.
Form 10-K for the Fiscal Year ended December 31, 2023
Response dated July 19, 2024
File No. 001-40873
Dear Gavin B. Brandon:
We have reviewed your July 19, 2024 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 a comment in our July 12, 2024 letter.
Form 10-K for the year ended December 31, 2023
Item 2. Properties, page 25
1.We acknowledge your response to prior comment 1. Please tell us, and in future filings,
please disclose, whether the Class B and Class C properties are concentrated either
geographically or by building type ( e.g., traditional office).
Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if you
have questions regarding comments on the financial statements and related matters. Please
contact Kibum Park at 202-551-6836 or Dorrie Yale at 202-551-8776 with any other questions.
Sincerely,
Division of Corporation Finance
August 1, 2024
Page 2
Office of Real Estate & Construction