United States securities and exchange commission logo
April 29, 2024
Steven Gallagher
Chief Accounting Officer
Brixmor Property Group Inc.
450 Lexington Avenue
New York, NY 10017
Re: Brixmor Property
Group Inc.
Form 10-K for the
year ended December 31, 2023
Filed February 12,
2024
Form 8-K
Filed February 12,
2024
File No. 001-36160
Dear Steven Gallagher:
We have reviewed your
filings and have the following comment.
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
the 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.
8-K filed February 12, 2024
Exhibit 99.2, page iv
1. We note your disclosure
of net principal debt to adjusted EBITDA, which is a non-GAAP
financial measure.
Please revise to include the disclosures required by Item 10(e) of
Regulation S-K,
including a reconciliation of the components of the ratio to the most
comparable GAAP
measures.
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 Ameen Hamady at 202-551-3891 or Kristina Marrone
at 202-551-3429 if
you have questions regarding comments on the financial statements and
related matters.
Steven Gallagher
Brixmor Property Group Inc.
April 29, 2024
Page 2
FirstName LastNameSteven Gallagher Sincerely,
Comapany NameBrixmor Property Group Inc.
Division of Corporation Finance
April 29, 2024 Page 2 Office of Real Estate & Construction
FirstName LastName