Accounting Non-GAAP Regulation S-X This category includes comments relating to financial statements and related notes as well as other performance metrics used by registrants. In 2023, 54 of the 71, or 76%, of the comments in this category were issued to listed REITs. In 2022, 45 of the 46, or 98%, 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. Financial Statements and Metrics Comments by Sub-Category Financial Statements and Metrics 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 ■ In order to better understand your current accounting and intended future accounting please provide us with your analysis under ASC 810 and ASC 323 such that you were able to conclude that you do not consolidate the operating partnership currently even though you have control and that even with such control you expect to account for the operating partnership initially as an equity method investment. ■ We note your segment measure of profit or loss is reconciled to income from operations as presented in your consolidated statements of operations. In future periodic filings, please reconcile your segments’ measure of profit or loss to consolidated income before income taxes. Refer to ASC 280-10-50-30b 27 2023 32 5 11 24 8 2022 A Comparative Analysis of 2022 and 2023 SEC Comments Issued to REITs | 8
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