SEC Comment Letter for Bluerock Homes Trust, (BHM) — Sep 30, 2025
Bluerock Homes Trust, Inc.
Date: Sept. 30, 2025 · CIK: 0001903382 · Accession: 0000000000-25-010713
AI Filing Summary & Sentiment
File numbers found in text: 001-41322
Referenced dates: August 1, 2025
Letter
September 30, 2025 Christopher J. Vohs Chief Financial Officer Bluerock Homes Trust, Inc. 919 Third Avenue 40th Floor New York, NY 10022 Re:Bluerock Homes Trust, Inc. Form 10-K for the fiscal year ended December 31, 2024 Response dated September 5, 2025 File No. 001-41322 Dear Christopher J. Vohs: We have reviewed your September 5, 2025 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. Form 10-K for the fiscal year ended December 31, 2024 Notes to Consolidated Financial Statements Note 3 - Acquisition of Real Estate, page F-15 1.We note from your response dated September 5, 2025 to prior comment 1 that a lender unaffiliated with the company financed the acquisition by funding $23.7M in first mortgage proceeds into title escrow. We further note that in your letter dated August 1, 2025, your view that all debt secured by an acquired real estate operation at closing – whether existing or in the form of new mortgage debt – should be excluded from the total investment as “assumed debt” for purposes of your significance calculation. Your calculation of the investment test does not comply with Rules 1- 02(w) and 3-14 of Regulation S-X. Therefore, it appears that the acquisition of the real estate operation is significant, and financial statements are required under Rule 3- 14 of Regulation S-X.
September 30, 2025 Page 2 Please contact Kellie Kim at 202-551-3129 or Isaac Esquivel at 202-551-3395 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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September 30, 2025
Christopher J. Vohs
Chief Financial Officer
Bluerock Homes Trust, Inc.
919 Third Avenue
40th Floor
New York, NY 10022
Re:Bluerock Homes Trust, Inc.
Form 10-K for the fiscal year ended December 31, 2024
Response dated September 5, 2025
File No. 001-41322
Dear Christopher J. Vohs:
We have reviewed your September 5, 2025 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.
Form 10-K for the fiscal year ended December 31, 2024
Notes to Consolidated Financial Statements
Note 3 - Acquisition of Real Estate, page F-15
1.We note from your response dated September 5, 2025 to prior comment 1 that a
lender unaffiliated with the company financed the acquisition by funding $23.7M in
first mortgage proceeds into title escrow. We further note that in your letter dated
August 1, 2025, your view that all debt secured by an acquired real estate operation at
closing – whether existing or in the form of new mortgage debt – should be excluded
from the total investment as “assumed debt” for purposes of your significance
calculation. Your calculation of the investment test does not comply with Rules 1-
02(w) and 3-14 of Regulation S-X. Therefore, it appears that the acquisition of the
real estate operation is significant, and financial statements are required under Rule 3-
14 of Regulation S-X.
September 30, 2025
Page 2
Please contact Kellie Kim at 202-551-3129 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction