November 13, 2019
CORRESPONDENCE FILING VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate and Commodities
100 F Street, N.E.
Washington, DC 20549
Attention: | Howard Efron, Staff Accountant | |||
Kristi Marrone, Staff Accountant |
Re: | SITE Centers Corp. | |||
Form10-K for the Year Ended December 31, 2018 | ||||
Response Dated September 30, 2019 | ||||
FileNo. 001-11690 |
Ladies and Gentlemen:
SITE Centers Corp., an Ohio corporation (the “Company” or “we,” “us” or “our”), is submitting this letter in response to the follow up letter from the staff (the “Staff”) of the Securities and Exchange Commission, dated November 8, 2019 (the “Comment Letter”), with respect to the Company’s Annual Report on Form10-K for the fiscal year ended December 31, 2018, filed February 27, 2019.
Below is the Company’s response. For the convenience of the Staff, the Company has repeated the Staff’s comment before the response.
Form10-K for the Year Ended December 31, 2018
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations SSNOI, page 46
1. | We note your response to comment one. We do not object to the current presentation of NOI or SSNOI of your unconsolidated joint ventures. However, it is still unclear how the presentation of “Total Consolidated + Unconsolidated NOI” and “Total SSNOI” at the 100% level is compliant with Question 100.04 of the Division’s Compliance and Disclosure Interpretations forNon-GAAP Financial Measures. Please confirm to us that you will remove “Total Consolidated + Unconsolidated NOI” at 100% and “Total NOI” at 100% from future periodic filings, including earnings releases, quarterly financial supplements and investor presentations filed on Form8-K. |
United States Securities and Exchange Commission
Division of Corporation Finance
Page 2
Response:
We will revise our disclosure of SSNOI in all future periodic filings, including earnings releases, quarterly financial supplements and investor presentations filed on Form8-K, to exclude the presentation of “Total Consolidated + Unconsolidated NOI” at 100% and “Total SSNOI” at 100%.
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If you have any questions regarding this matter, please do not hesitate to contact the undersigned at646-868-4765.
Very truly yours, |
/s/ Matthew L. Ostrower |
Matthew L. Ostrower |
Executive Vice President, |
Chief Financial Officer and Treasurer |
cc: | Christa A Vesy, Executive Vice President, |
and Chief Accounting Officer