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United States securities and exchange commission logo
May 6, 2024
Barry N. Berlin
Chief Financial Officer
Creative Media & Community Trust Corp
5956 Sherry Lane, Suite 700
Dallas, TX 75225
Re: Creative Media &
Community Trust Corp
Form 10-K for
Fiscal Year Ended December 31, 2023
File No. 001-13610
Dear Barry N. Berlin:
We have reviewed your
filing and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Annual Report on Form 10-K for fiscal year ended December 31, 2023
Item 1. Business, page 2
1. We note your disclosure
in footnote one on page 53 that a tenant exercised their early
termination right in
2023 and that on page 23 you indicate that tenants may be able to
exercise their early
termination rights, to the extent available. Please tell us and revise
future filings to
clarify the percentage of your occupied properties that have tenants with
early termination
provisions and discuss the impact to you from tenants exercising such
provisions, including
the number of tenants that have exercised that provision over the
past two years and the
amount of impacted square footage.
Item 2. Properties, page 50
2. We note your disclosure
on page 50 that one office property is being partially converted
into multifamily use,
that your Unconsolidated Joint Ventures contain one multifamily site
currently under
development, and that you have several other properties to be developed,
potentially into
multifamily. Please tell us and revise future filings to disclose the
anticipated completion
date, scope of development, costs incurred to date and budgeted
costs for any sites
currently under development.
Barry N. Berlin
Creative Media & Community Trust Corp
May 6, 2024
Page 2
3. We note your definition of annualized rent on page 1. We also note that
you have included
footnote disclosure regarding the impact of abatements on your office
properties in
footnote 3 on page 57, but you did not include the impact of abatements
in your footnote
disclosure to the office property tables on page 58. Further, we note
that you did not
include disclosure regarding the impact of free rent, tenant
reimbursements, and tenant
concessions on page 58 for your multifamily properties. Please tell us
and revise future
filings to disclose your average effective annual rent per square foot
and add footnote
disclosure to clarify how the average effective rent takes into account
tenant concessions
and abatements.
4. We refer to your statement on page 2 that you are focused on Class A and
creative office
real assets. For each property, please tell us and revise future filings
to disclose the class
of the office building. Please clarify if the class of building is
impacting your ability to
renew leases or obtain new tenants, and the impact on leasing costs
associated with
renewing or re-letting a particular space.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Kellie Kim at 202-551-3129 or Kristina Marrone at
202-551-3429 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Stacie Gorman at 202-551-3585 with
any other
questions.
Sincerely,
FirstName LastNameBarry N. Berlin
Division of Corporation
Finance
Comapany NameCreative Media & Community Trust Corp
Office of Real Estate &
Construction
May 6, 2024 Page 2
cc: Patrick S. Brown
FirstName LastName