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United States securities and exchange commission logo
December 8, 2020
Matthew DiLiberto
Chief Financial Officer
SL Green Realty Corp. and SL Green Operating Partnership, L.P.
420 Lexington Avenue
New York, NY 10170
Re: SL Green Realty
Corp.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed February 28,
2020
File No. 001-13199
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SL Green Operating
Partnership, L.P.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed February 28,
2020
File No.
333-167793-02
Dear Mr. DiLiberto:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Notes to Consolidated Financial Statements
Note 3. Property Acquisitions, page 91
1. Please tell us how your
acquisition of a majority and controlling 70.87% interest in 410
Tenth Avenue resulted
in the recognition of a $67.6 million gain. Please address the
following in your
response:
Explain whether
the acquisition was accounted for as a business combination or an
asset acquisition
and provide us with the basis for your conclusion.
Matthew DiLiberto
SL Green Realty Corp. and SL Green Operating Partnership, L.P.
December 8, 2020
Page 2
In your Form 10-Q for the quarterly period ended June 30, 2019,
we note that you
recorded a $67 million gain as a result of the acquisition of a
majority and controlling
interest in 460 West 34th Street. Clarify for us if this
acquisition was related to your
acquisition of a controlling interest in 410 Tenth Avenue.
Note 5. Debt and Preferred Equity Investments, page 93
2. Please tell us how you considered the need to disclose the recorded
balance in debt and
preferred equity investments by risk level. Reference is made to ASC
Topic 310-10-50-
29.
In closing, 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.
You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Robert
Telewicz,
Accounting Branch Chief at (202) 551-3438 with any questions.
FirstName LastNameMatthew DiLiberto Sincerely,
Comapany NameSL Green Realty Corp. and SL Green Operating Partnership, L.P.
Division of Corporation
Finance
December 8, 2020 Page 2 Office of Real Estate &
Construction
FirstName LastName