SEC Comment Letter 0000000000-23-008059 to Blue Owl Real Estate Net Lease Trust (CIK 0001944366)
Blue Owl Real Estate Net Lease Trust (CIK 0001944366)
Date: July 27, 2023 · CIK: 0001944366 · Accession: 0000000000-23-008059
AI Filing Summary & Sentiment
File numbers found in text: 000-56536
Letter
United States securities and exchange commission logo July 27, 2023 Kevin Halleran Chief Financial Officer Blue Owl Real Estate Net Lease Trust 30 N. LaSalle St., Suite 4140 Chicago, IL 60602 Re:Blue Owl Real Estate Net Lease Trust Post-effective Amendment No. 1 to Registration Statement on Form 10-12G Filed June 26, 2023 File No. 000-56536 Dear Kevin Halleran: We have reviewed your filing and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to the comment, we may have additional comments. Post-effective Amendment No. 1 to Form 10-12G Item 1. Business Share Repurchase Plan, page 28 1.We acknowledge your response and revised disclosures to prior comment 3, and note your statement that you intend to conduct repurchase offers under the New Repurchase Plan in accordance with the requirements of Rule 13e-4. We also note your disclosure that the repurchase price that will be equal to the NAV per share as of the valuation date will not be available until after the expiration of the applicable tender offer, so shareholders will not know the exact price of shares in the tender offer when they make a decision whether to tender their shares. We also note that shareholders are not able to withdraw their request to tender shares after the repurchase price is known, as that will occur following the expiration of the tender offer. Please explain to us how you expect to conduct your New Repurchase Plan in accordance with Rule 13e-4, and whether you expect to file a
FirstName LastNameKevin Halleran Comapany NameBlue Owl Real Estate Net Lease Trust July 27, 2023 Page 2 FirstName LastName Kevin Halleran Blue Owl Real Estate Net Lease Trust July 27, 2023 Page 2 Schedule TO for each repurchase. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Mark Rakip at 202-551-3573 or Robert Telewicz at 202-551-3438 if you have questions regarding comments on the financial statements and related matters. Please contact Stacie Gorman at 202-551-3585 or Dorrie Yale at 202-551-8776 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Benjamin Wells, Esq.
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United States securities and exchange commission logo
July 27, 2023
Kevin Halleran
Chief Financial Officer
Blue Owl Real Estate Net Lease Trust
30 N. LaSalle St., Suite 4140
Chicago, IL 60602
Re:Blue Owl Real Estate Net Lease Trust
Post-effective Amendment No. 1 to Registration Statement on Form 10-12G
Filed June 26, 2023
File No. 000-56536
Dear Kevin Halleran:
We have reviewed your filing and have the following comment. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to the comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to
the comment, we may have additional comments.
Post-effective Amendment No. 1 to Form 10-12G
Item 1. Business
Share Repurchase Plan, page 28
1.We acknowledge your response and revised disclosures to prior comment 3, and note your
statement that you intend to conduct repurchase offers under the New Repurchase Plan in
accordance with the requirements of Rule 13e-4. We also note your disclosure that the
repurchase price that will be equal to the NAV per share as of the valuation date will not
be available until after the expiration of the applicable tender offer, so shareholders will
not know the exact price of shares in the tender offer when they make a decision whether
to tender their shares. We also note that shareholders are not able to withdraw their
request to tender shares after the repurchase price is known, as that will occur following
the expiration of the tender offer. Please explain to us how you expect to conduct your
New Repurchase Plan in accordance with Rule 13e-4, and whether you expect to file a
FirstName LastNameKevin Halleran
Comapany NameBlue Owl Real Estate Net Lease Trust
July 27, 2023 Page 2
FirstName LastName
Kevin Halleran
Blue Owl Real Estate Net Lease Trust
July 27, 2023
Page 2
Schedule TO for each repurchase.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Mark Rakip at 202-551-3573 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters. Please
contact Stacie Gorman at 202-551-3585 or Dorrie Yale at 202-551-8776 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Benjamin Wells, Esq.