SEC Comment Letter 0000000000-23-013475 to Sculptor Diversified Real Estate Income Trust, Inc. (CIK 0001914496)
Sculptor Diversified Real Estate Income Trust, Inc. (CIK 0001914496)
Date: Dec. 11, 2023 · CIK: 0001914496 · Accession: 0000000000-23-013475
AI Filing Summary & Sentiment
Letter
December 8, 2023 Steven Orbuch Chairman and Chief Executive Officer Sculptor Diversified Real Estate Income Trust, Inc. 9 West 57th Street, 40th Floor New York, NY 10019
Re: Sculptor Diversified Real Estate Income Trust, Inc. Amended Registration Statement on Form 10 Filed August 15, 2023 File No. 000 -56566
Dear Steven Orbuch :
We received your letters dated August 15 , 2023 and September 13 , 2023 , which you provided in response to staff comments in connection with the review of your Form 10 filed July 5, 2023 and a post -effective amendment to that Form 10 filed September 13, 2023 . Given your significant asset concentration due to triple -net lease arrangement s with subsidiaries of Sevita as well as guarantee agreements by Sevita , we believe that the financial statements of S evita are necessary for an adequate presentation of your financial condition . Based on the information you provided in your letters and pu rsuant to our authority in Rule 3 -13 of Regulation S -X, we require that you amend your Form 10 to include audited financial statements of Sevita as of and for the year ended December 31, 2022 . If you have any questions regarding this letter, please call me at (202) 551 -3782.
Sincerely,
/s/ Jessica Barberich
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December 8, 2023 Steven Orbuch Chairman and Chief Executive Officer Sculptor Diversified Real Estate Income Trust, Inc. 9 West 57th Street, 40th Floor New York, NY 10019 Re: Sculptor Diversified Real Estate Income Trust, Inc. Amended Registration Statement on Form 10 Filed August 15, 2023 File No. 000 -56566 Dear Steven Orbuch : We received your letters dated August 15 , 2023 and September 13 , 2023 , which you provided in response to staff comments in connection with the review of your Form 10 filed July 5, 2023 and a post -effective amendment to that Form 10 filed September 13, 2023 . Given your significant asset concentration due to triple -net lease arrangement s with subsidiaries of Sevita as well as guarantee agreements by Sevita , we believe that the financial statements of S evita are necessary for an adequate presentation of your financial condition . Based on the information you provided in your letters and pu rsuant to our authority in Rule 3 -13 of Regulation S -X, we require that you amend your Form 10 to include audited financial statements of Sevita as of and for the year ended December 31, 2022 . If you have any questions regarding this letter, please call me at (202) 551 -3782. Sincerely, /s/ Jessica Barberich Jessica Barberich Associate Chief Accountant For the Commission, by the Division of Corporation Finance, pursuant to delegated authority.