0001104659-21-004160.txt : 20210216 0001104659-21-004160.hdr.sgml : 20210216 20210114125236 ACCESSION NUMBER: 0001104659-21-004160 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210114 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Broadmark Realty Capital Inc. CENTRAL INDEX KEY: 0001784797 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 842620891 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1420 FIFTH AVENUE STREET 2: SUITE 2000 CITY: SEATTLE STATE: WA ZIP: 98101 BUSINESS PHONE: 206-971-0800 MAIL ADDRESS: STREET 1: 1420 FIFTH AVENUE STREET 2: SUITE 2000 CITY: SEATTLE STATE: WA ZIP: 98101 FORMER COMPANY: FORMER CONFORMED NAME: Trinity Sub Inc. DATE OF NAME CHANGE: 20190806 CORRESP 1 filename1.htm

BROADMARK REALTY CAPITAL INC.

January 14, 2021

VIA EDGAR

Office of Real Estate & Construction

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549-7010

Attention:	Ruari Regan / David Link / Jennifer Monick

Re:	Broadmark Realty Capital Inc.
	Registration Statement on Form S-3
	File No. 333-251075

Broadmark Realty Capital Inc. (the “Company” or “Broadmark Realty”) submits this letter in response to the oral comment relating to Amendment No. 1 to the Company’s Registration Statement on Form S-3 filed January 4, 2021 (the “Registration Statement”) provided by the staff (the “Staff”) of the U.S. Securities and Exchange Commission to our counsel by telephone on January 13, 2021. Capitalized terms used but not defined herein shall have the meanings assigned to such terms in the Registration Statement.

We understand that the Staff notes the Company’s response to prior comment 1 indicating that the Company has excluded the summarized combined financial information for the subsidiary guarantors as the assets, liabilities and results of operations of the combined parent issuer and the subsidiary guarantors are not materially different than the corresponding amounts presented in the consolidated financial statements of Broadmark Realty, and has requested that the Company revise the filing to disclose the foregoing.

In response to the Staff’s oral comment, we will add the following disclosure under the caption “Supplemental Guarantor Information” on page 3 of the prospectus included in the Registration Statement:

We have omitted summarized financial information for the issuers and guarantors of the securities offered hereby because the combined assets, liabilities and results of operations of the issuers and the guarantors are not materially different than the corresponding amounts presented in the consolidated financial statements of Broadmark Realty.

***

We would appreciate the Staff’s prompt review of this response. Upon confirmation that the Staff has no further comments, the Company will promptly file an amendment to the Registration Statement reflecting the response above and seek acceleration of the effectiveness of the Registration Statement as soon as possible. Please contact the undersigned at (908) 727-0589 or Eliot W. Robinson at (404) 572-6785 should you require further information or have any questions.

		Very truly yours,

		/s/ David Schneider
		David Schneider
		Chief Financial Officer

cc:	Jeffrey Pyatt (Broadmark Realty Capital Inc.)
	Nevin Boparai (Broadmark Realty Capital Inc.)
	Eliot W. Robinson, Esq. (Bryan Cave Leighton Paisner LLP)