United States securities and exchange commission logo
May 29, 2024
Kevin M. Fennell
Executive Vice President and Chief Financial Officer
Broadstone Net Lease, Inc.
207 High Point Dr., Suite 300
Victor, NY 14564
Re: Broadstone Net
Lease, Inc.
Form 10-K for the
year ended December 31, 2023
Form 10-Q for the
quarter ended March 31, 2024
File No. 001-39529
Dear Kevin M. Fennell:
We have limited our review of your filing to the financial
statements and related
disclosures 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 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.
Form 10-Q for the quarter ended March 31, 2024
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
19
1. Since February 2023, we
note that earnings calls have emphasized that current market
conditions have
adversely impacted commercial real estate net lease markets and caused
significant declines in
transaction levels. We also note that in the first quarter of 2024,
you have sold 37 assets
within your healthcare portfolio and intend to sell clinical,
surgical and
traditional medical office building properties, which has not always fit well
within the traditional
net lease framework, so that you can focus more intently on
industrial space and
your other core investment verticals of retail and restaurant assets.
Please tell us and
revise future disclosures to provide more robust discussion related to
known trends or
uncertainties that are reasonably likely to have a material impact on your
cash flows, liquidity,
capital resources, cash requirements, financial position, or results of
operations related to
conditions in the market or your specific strategies within your
Management s
Discussion and Analysis of Financial Condition and Results of Operations.
Kevin M. Fennell
Broadstone Net Lease, Inc.
May 29, 2024
Page 2
Reference is made to Item 303 of Regulation S-K.
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.
Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468
with any
questions.
FirstName LastNameKevin M. Fennell Sincerely,
Comapany NameBroadstone Net Lease, Inc.
Division of
Corporation Finance
May 29, 2024 Page 2 Office of Real
Estate & Construction
FirstName LastName