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VIA EDGAR

 

October 26, 2020

 

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate and Construction

100 F Street, N.E.

Washington, D.C. 20549

 

 

Form 10-K for the year ended December 31, 2019

Form 10-Q for the quarterly period ended March 31, 2020

Form 10-Q for the quarterly period ended June 30, 2020

File No. 001-38082

 

Dear Mr. Lewis and Ms. Menjivar,

 

KKR Real Estate Finance Trust Inc. (the “Company,” “KREF”, “we” or “our”) is submitting the following response to your comment letter, dated October 14, 2020, regarding the Company’s Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2020.  To assist your review, we have retyped the text of the Staff’s most recent comment in italics below. 

 

 

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1.          We have considered your response to comment 1 in our letter dated July 20, 2020.  We continue to believe that your presentation of Core Earnings, which excludes the unrealized portion of the provision for credit losses, appears to substitute individually tailored recognition and measurement methods for those of GAAP and could violate Rule 100(b) of Regulation G, as discussed in Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please refrain from disclosing this performance measure, or any other performance measures that exclude the provision for credit losses, or portions of the provision for credit losses, in future filings.

Response:

While we respectfully disagree with the Staff’s position that the Company’s current Core Earnings presentation substitutes individually tailored recognition and measurement methods for those of GAAP in violation of Rule 100(b) of Regulation G, as discussed in Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations, we will refrain from excluding the provision for credit losses, or portions of the provision for credit losses, from our Core Earnings presentation in future filings.  Further to our discussion with the Staff on October 19, 2020, we will implement this reporting change beginning with our Annual Report on Form 10-K for the fiscal year ending December 31, 2020, and in all subsequent reporting periods.

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We hope the foregoing addresses the Staff’s comment. If you have any questions or comments regarding the foregoing, please do not hesitate to contact me at (212) 520-1537.

 

Sincerely,

 

/s/ Mostafa Nagaty

Mostafa Nagaty

Chief Financial Officer

 

 

 

 

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