An Analysis of 2021 and 2022 SEC Comments Issued to REITs

Financial Statements and Metrics Comments by Sub-Category Accounting Non-GAAP Regulation S-X 24 50 19 Financial Statements and Metrics This category includes comments relating to financial statements and related notes as well as other performance metrics used by registrants. 84 of the 100, or 84%, of the comments in this category were issued to listed REITs. Within this category, there are three major sub-categories: comments related to the company’s accounting treatment; comments related to the use of non-GAAP financial measures; and comments related to providing the relevant information required under Regulation S-X. Accounting The Staff is often focused on how the Accounting Standards Codification (“ ASC ”) has been interpreted and applied as well as financial statement presentation and footnote disclosure. Frequent topics of comment include: ■ Variable Interest Entity and Joint Venture accounting in accordance with ASC 10 and 323; and ■ Segment reporting under ASC 280. Sample Comments ■ Describe how the Company considered the variable interest guidance in ASC 810-10-15-14 and whether the acquisition resulted in an acquired VIE. ■ We note your recent increase in your portfolio of consolidated joint ventures equity investments in multi-family properties. In light of that increase, please tell us if you continue to have only one reportable segment and tell us how you made your determination. Within your response, please refer to ASC 280. An Analysis of 2021 and 2022 SEC Comments Issued to REITs | 8