SEC Comment Letter 0000000000-24-002941 to Sculptor Diversified Real Estate Income Trust, Inc. (CIK 0001914496)
Sculptor Diversified Real Estate Income Trust, Inc. (CIK 0001914496)
Date: March 18, 2024 · CIK: 0001914496 · Accession: 0000000000-24-002941
AI Filing Summary & Sentiment
Referenced dates: December 8, 2023, January 24, 2024
Letter
March 15, 2024 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 letter dated January 24, 2024, which you provided in response to our letter dated December 8, 2023 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 co ncentration due to triple -net lease arrangements with subsidiaries of Sevita as well as guarantee agreements by Sevita , we continue to believe that the financial statements of Sevita are necessary for an adequate presentation of your financial condition . Based on the information you provided in your letters and pursuant to our authority in Rule 8-01(e) 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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March 15, 2024 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 letter dated January 24, 2024, which you provided in response to our letter dated December 8, 2023 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 co ncentration due to triple -net lease arrangements with subsidiaries of Sevita as well as guarantee agreements by Sevita , we continue to believe that the financial statements of Sevita are necessary for an adequate presentation of your financial condition . Based on the information you provided in your letters and pursuant to our authority in Rule 8-01(e) 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 auth ority.