United States securities and exchange commission logo
April 24, 2024
Michael J. Bilerman
Chief Financial Officer
Tanger Inc.
3200 Northline Avenue
Suite 360
Greensboro, NC 27408
Re: Tanger Inc.
Form 10-K for the
fiscal year ended December 31, 2023
Filed February 21,
2024
File No. 001-11986
Dear Michael J. Bilerman:
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
this 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-K filed February 21, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Evaluation of Impairment of long-lived assets, page 60
1. We note that one of
your centers has an estimated fair value less than its recorded carrying
value of approximately
$ 111.1 million and that you are monitoring for circumstances and
events in future
periods that could affect inputs such as the expected holding period,
operating cash flow
forecasts and capitalization rates utilized to determine whether an
impairment charge is
necessary. Please tell us, and consider disclosing in future filings:
the identity of the
center in question
how you applied the
guidance in ASC 360-10-35-29 to 35 and the Interpretative
Response to
Question 3 of ASC 360-10-S99-2 in your impairment analysis
how you determined
that the carrying value of the center is recoverable, and
how you considered
the disclosure guidance in Item 303(b)(3) of Regulation S-K.
Michael J. Bilerman
Tanger Inc.
April 24, 2024
Page 2
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 Peter McPhun at 202-551-3581 or Kristina Marrone at
202-551-3429 with
any questions.
FirstName LastNameMichael J. Bilerman Sincerely,
Comapany NameTanger Inc.
Division of
Corporation Finance
April 24, 2024 Page 2 Office of Real Estate
& Construction
FirstName LastName