RAIT Financial Trust
Cira Centre
2929 Arch Street, 17th Floor
Philadelphia, PA 19104
January 22, 2013
VIA EDGAR AND OVERNIGHT MAIL
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-0405
Attn: Daniel L. Gordon, Branch Chief
Re: | RAIT Financial Trust | |
Form 10-K for the year ended December 31, 2011 | ||
Filed February 24, 2012 | ||
File No. 001-14760 |
Dear Mr. Gordon:
On behalf of RAIT Financial Trust (RAIT), this letter is to respond to your comment letter dated January 10, 2013 concerning the above-referenced filing. For your convenience, we first restate your comment in italics and then provide RAITs response.
Form 10-K for the Fiscal Year Ended December 31, 2011 filed February 24, 2012
Consolidated Statements of Operations, page 82
1. | We note your response to comment two in our letter dated December 4, 2012. Given that a significant portion of your interest bearing liabilities continue to finance a significant portion of your interest earning assets, we continue to believe that you should use a net interest income presentation consistent with Article 9 of Regulation S-X. Please revise in future filings. |
Response: RAIT will provide the requested disclosure in future filings.
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With regard to the Forms discussed above, RAIT acknowledges the following:
| RAIT is responsible for the adequacy and accuracy of the disclosure in the filing; |
| staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| RAIT may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
If you have any questions or comments regarding the foregoing, or have additional questions or comments, please contact the undersigned at (215) 243-9000.
Very truly yours, | ||
/s/ James J. Sebra | ||
Name: | James J. Sebra | |
Chief Financial Officer and Treasurer |