Correspondence 0001104659-25-007885 from BGO Industrial Real Estate Income Trust, Inc. (CIK 0001942722)
BGO Industrial Real Estate Income Trust, Inc. (CIK 0001942722)
Date: Jan. 31, 2025 · CIK: 0001942722 · Accession: 0001104659-25-007885
AI Filing Summary & Sentiment
File numbers found in text: 333-271906
Referenced dates: November 15, 2024
Letter
VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction Washington, D.C. 20549 Re: BGO Industrial Real Estate Income Trust, Inc. Form 10-K for the year ended December 31, 2023 File No. 333-271906
Dear Mr. McPhee and Mr. Lee:
This letter sets forth the response of BGO Industrial Real Estate Income Trust, Inc. (the “Company”) to the comment letter of the staff of the Securities and Exchange Commission (the “Staff”), dated November 15, 2024, relating to the above-referenced filing. To assist your review, we have retyped the text of the Staff’s comment in italics below and provided the Company’s response thereto immediately below each comment.
U.S. Securities and Exchange Commission January 31,
Item 5. Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer
Purchases of Equity Securities
Net Asset Value, page 82
1. Please consider expanding future disclosures of net asset value to provide a quantitative illustration of the sensitivity of your valuation to changes in key assumptions.
Response: The Company intends to expand its disclosure to include the following quantitative illustration of the sensitivity of the Company’s valuation to changes in its key assumptions in future periodic reports filed with U.S. Securities and Exchange Commission, beginning with the Company’s Annual Report on Form 10-K for the year ended December 31, 2024:
A change in the exit capitalization and discount rates used would impact the calculation of the value of our real properties. For example, assuming all other factors remain constant, the changes listed below would result in the following effects on the value of our real properties, excluding certain newly acquired properties that are currently held at cost which we believe reflects the fair value of such properties:
Input
Hypothetical
Change
Increase
(Decrease) to
the NAV of
Real
Properties
Discount Rate
0.25% decrease
[ ]%
(weighted average)
0.25% increase
[ ]%
Exit Capitalization Rate
0.25% decrease
[ ]%
(weighted average)
0.25% increase
[ ]%
*****
Please do not hesitate to call me at (202) 636-5924 or Ryan Bekkerus at (212) 455-2293 with any questions or further comments you may have regarding this filing or if you wish to discuss the above responses.
Very truly yours,
/s/ Daniel B. Honeycutt
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filename1.htm
Simpson Thacher & Bartlett llp
425 Lexington
Avenue
New York,
NY 10017
telephone:
+1-212-455-2000
facsimile:
+1-212-455-2502
Direct Dial Number
+1-202-636-5924
E-mail Address
daniel.honeycutt@stblaw.com
January 31, 2025
VIA EDGAR
Mr. Eric McPhee
Mr. Wilson Lee
Division of Corporation Finance
Office of Real Estate & Construction
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: BGO Industrial Real Estate Income Trust, Inc.
Form 10-K for the year ended December 31, 2023
File No. 333-271906
Dear
Mr. McPhee and Mr. Lee:
This letter
sets forth the response of BGO Industrial Real Estate Income Trust, Inc. (the “Company”) to the comment letter
of the staff of the Securities and Exchange Commission (the “Staff”), dated November 15, 2024, relating to the above-referenced
filing. To assist your review, we have retyped the text of the Staff’s comment in italics below and provided the Company’s
response thereto immediately below each comment.
U.S.
Securities and Exchange Commission
2
January 31,
2025
Item 5. Market for Registrant’s
Common Equity, Related Stockholder Matters and Issuer
Purchases of Equity Securities
Net Asset Value, page 82
1. Please consider expanding future disclosures of net asset value to
provide a quantitative illustration of the sensitivity of your valuation to changes in key
assumptions.
Response:
The Company intends to expand its disclosure to include the following quantitative illustration of the sensitivity of the Company’s
valuation to changes in its key assumptions in future periodic reports filed with U.S. Securities and Exchange Commission, beginning
with the Company’s Annual Report on Form 10-K for the year ended December 31, 2024:
A change in the exit capitalization and
discount rates used would impact the calculation of the value of our real properties. For example, assuming all other factors remain
constant, the changes listed below would result in the following effects on the value of our real properties, excluding certain newly
acquired properties that are currently held at cost which we believe reflects the fair value of such properties:
Input
Hypothetical
Change
Increase
(Decrease) to
the NAV of
Real
Properties
Discount Rate
0.25% decrease
[
]%
(weighted average)
0.25% increase
[
]%
Exit Capitalization Rate
0.25% decrease
[
]%
(weighted average)
0.25% increase
[
]%
*****
Please do
not hesitate to call me at (202) 636-5924 or Ryan Bekkerus at (212) 455-2293 with any questions or further comments you may have
regarding this filing or if you wish to discuss the above responses.
Very truly yours,
/s/ Daniel B. Honeycutt
Daniel B. Honeycutt
cc:
BGO Industrial Real Estate Income
Trust, Inc.
Lori Biancamano, Chief Financial Officer and Treasurer
Clint Hinds, Chief
Executive Officer
Matthew Campbell, Secretary