SEC Comment Letter 0000000000-23-009364 to Blue Owl Real Estate Net Lease Trust (CIK 0001944366)
Blue Owl Real Estate Net Lease Trust (CIK 0001944366)
Date: Aug. 24, 2023 · CIK: 0001944366 · Accession: 0000000000-23-009364
AI Filing Summary & Sentiment
File numbers found in text: 000-56536
Letter
United States securities and exchange commission logo August 24, 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 Response Dated August 2, 2023 File No. 000-56536 Dear Kevin Halleran: We have reviewed your August 2, 2023 response to our comment letter 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. Correspondence dated August 2, 2023 General 1.We note your response to comment 1. We are unable to agree that your contemplated repurchase program, as described to us in your registration statement, your response, and on several calls with your counsel, complies with the requirements of Rule 13e-4 and Schedule TO. Please revise your redemption plan to comply with the specifics of prior no-action relief, or otherwise explain how you will comply with the requirements of Rule 13e-4. 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
FirstName LastNameKevin Halleran Comapany NameBlue Owl Real Estate Net Lease Trust August 24, 2023 Page 2 FirstName LastName Kevin Halleran Blue Owl Real Estate Net Lease Trust August 24, 2023 Page 2 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
August 24, 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
Response Dated August 2, 2023
File No. 000-56536
Dear Kevin Halleran:
We have reviewed your August 2, 2023 response to our comment letter 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.
Correspondence dated August 2, 2023
General
1.We note your response to comment 1. We are unable to agree that your contemplated
repurchase program, as described to us in your registration statement, your response, and
on several calls with your counsel, complies with the requirements of Rule 13e-4 and
Schedule TO. Please revise your redemption plan to comply with the specifics of prior
no-action relief, or otherwise explain how you will comply with the requirements of Rule
13e-4.
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
FirstName LastNameKevin Halleran
Comapany NameBlue Owl Real Estate Net Lease Trust
August 24, 2023 Page 2
FirstName LastName
Kevin Halleran
Blue Owl Real Estate Net Lease Trust
August 24, 2023
Page 2
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.