April 11, 2018
VIA EDGAR AND FEDEX
Kristi Marrone
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate and Commodities
100 F Street, N.E.
Washington, D.C. 20549
Re: | Apollo Commercial Real Estate Finance, Inc. |
Form 10-K for the fiscal year ended December 31, 2017
Filed February 14, 2018
FileNo. 1-34452
Dear Ms. Marrone:
On behalf of Apollo Commercial Real Estate Finance, Inc., a Maryland corporation (the“Company”), set forth below are the responses of the Company to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated April 10, 2018 (the “Comment Letter”) with respect to the Company’s Form10-K for the year ended December 31, 2017 (the “Form10-K”).
The Company’s responses to the comments of the Staff contained in the Comment Letter are set out below in the order in which the comments were set out in the Comment Letter and are numbered accordingly. Defined terms used herein but not otherwise defined have the meanings given to them in the Form10-K.
Consolidated Balance Sheets, page 52
1. | We note your response to comment 2. Given that your lenders have the contractual right to sell or repledge the collateral assets in your repurchase agreements, we continue to believe that such encumbered assets should be presented separately on the face of your balance sheet in future filing in accordance with ASC860-30-45-1. |
Company Response:
The Company notes the Staff’s comment and will identify the encumbered assets parenthetically on the face of the balance sheet in future filings.
* * * * *
Should the Staff have additional questions or comments regarding any of the foregoing, please do not hesitate to contact the undersigned at (212)822-0493 or Jay L. Bernstein or Andrew S. Epstein of Clifford Chance US LLP, counsel to the Company at (212)878-8527 or (212)878-8332.
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Sincerely, |
/s/ Jai Agarwal |
Jai Agarwal |
Chief Financial Officer, Treasurer and Secretary |
cc: | Securities and Exchange Commission |
Becky Chow
Apollo Commercial Real Estate Finance, Inc.
Stuart A. Rothstein
Clifford Chance US LLP
Jay L. Bernstein
Andrew S. Epstein
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