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EXRExtra Space Storage

Real estate · REIT · NYSE
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SEC comment letters, last 20 years

1 review of EXR's filings by SEC staff

UPLOAD and CORRESP
ReviewsRead ↓
1
latest letter 2017-04-10
Questions asked
3
each answered in the company's own letter
No closing letter
0
reviews without a letter saying the staff completed it

When the SEC's staff reviews a filing, it writes to the company with numbered questions, and the company answers each one in a letter. SEC publishes the exchange once the review is over, at least 20 business days later. A question is not an accusation; most reviews end with the company adding detail to its next filing.

Form 10-K

2017-04-10 to 2017-04-19 · 3 questions · 1 letter from the SEC, 1 from the company
Review closed 2017-04-19
Non-GAAP measuresAcquisitions
Form 10-K for the year ended December 31, 2016 · Same-Store Results, page 33
SEC asked (1)
Please revise your reconciliation in future filings to begin with net income, the most directly comparable measure, ensuring that the non-GAAP measure does not receive undue prominence. See Question 102.10 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Notes to Consolidated Financial Statements 4. Property Acquisitions and Dispositions, page 60
EXR answered

No numbered answer found in the reply. Read the reply ↗

In its next report

First report after the company's reply of 2017-04-17: 10-Q filed 2017-05-05 ↗, against the 10-Q filed 2016-11-04 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Form 10-K for the year ended December 31, 2016 · Same-Store Results, page 33
SEC asked (2)
We note that the amounts disclosed in the table for the number and value of OP Units issued during 2016 do not agree to the amounts disclosed in Note 13. Please tell us the actual number of OP Units issued during 2016 and the value of those units, and clarify or revise your disclosure in future filings.
Rest of the question

To the extent the value assigned to issued OP Units varies significantly, please tell us the reason for such variances.

EXR answered

No numbered answer found in the reply. Read the reply ↗

In its next report

First report after the company's reply of 2017-04-17: 10-Q filed 2017-05-05 ↗, against the 10-Q filed 2016-11-04 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Exhibit 99.1 · Outlook
SEC asked (3)
We note you provide certain non-GAAP same-store outlook numbers. In future Form 8- K 2.02 filings, please follow the guidance in C&DI Question 102.10 and provide the reconciliations required by Item 10(e)(1)(i) of Regulation S-K.
EXR answered

No numbered answer found in the reply. Read the reply ↗

In its next report

First report after the company's reply of 2017-04-17: 10-Q filed 2017-05-05 ↗, against the 10-Q filed 2016-11-04 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Also in this review: closing letter, 2017-04-19

Other letters

Letters without questions

UPLOAD and CORRESP
4 other letters: notices that a filing will not be reviewed, requests to declare a registration effective, and the like

From the SEC's correspondence on EDGAR: staff letters (form UPLOAD) and company letters (form CORRESP), 13 letters filed since 2016-08-08. Questions and answers are matched by their numbers; topics come from words in each question. The reports are compared word for word (same form, before the first SEC letter against the first report after the company's reply). No AI.

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