July 16, 2024
Gordon Harper
Chief Financial Officer, Controller and Secretary
Armour Residential REIT, Inc.
3001 Ocean Drive
Suite 201
Vero Beach, FL 32963
Re: Armour Residential REIT, Inc.
Form 10-K for the Fiscal Year Ending December 31, 2023
Filed March 15, 2024
File No. 001-34766
Dear Gordon Harper:
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
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.
Form 10-K for the Fiscal Year Ending December 31, 2023
Management's Discussion and Analysis
Results of Operations, page 49
1. We note your disclosure on page 113 stating that net interest margin
contains a non-
GAAP financial measure and thus "SEC filings should include enhanced
disclosures in
accordance with applicable SEC guidance." However, on page 49, you make
reference
that changes were made in the fourth quarter of 2023 and that your prior
presentation of
Net Interest Margin is a non-GAAP financial measure. It appears the
current
presentation on page 49 no longer contains aspects of a Non-GAAP
financial measure.
Please confirm and/or clarify whether this is the case. To the extent
the current
presentation is still a non-GAAP financial measure, please clarify
and/or revise
accordingly to comply with the disclosure requirements of Item 10(e) of
Regulation S-K.
July 16, 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 Babette Cooper at 202-551-3396 or Wilson Lee at
202-551-3468 with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Real Estate
& Construction