United States securities and exchange commission logo
May 13, 2021
Daniel Guglielmone
Executive Vice President - Chief Financial Officer
FEDERAL REALTY INVESTMENT TRUST
909 Rose Avenue, Suite 200
North Bethesda , Maryland 20852
Re: FEDERAL REALTY
INVESTMENT TRUST
Form 10-K for
Fiscal Year Ended December 31, 2020
Filed February 11,
2021
File No. 001-07533
Dear Mr. Guglielmone:
We have reviewed your filing and have the following comment. In
our comment, we
may ask you to provide us with information so we may better understand
your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2020
Item 7. Managment's Discussion and Analysis of Financial Condition and
Results of Operations
Property Operating Income , page 42
1. We note you present
property operating income as a Non-GAAP measure. It appears the
reconciliation of
operating income to property operating income included in prior annual
reports has been
removed from the current annual report. Please revise your future filings
to include this
reconciliation to comply with the requirements outlined within paragraph
10(e)(i)(B) of
Regulation S-K.
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.
You may contact Paul Cline at 202-551-3851 or Wilson Lee at
202-551-3468 with any
other questions.
Daniel Guglielmone
FEDERAL REALTY INVESTMENT TRUST
May 13, 2021
Page 2
FirstName LastNameDaniel Guglielmone Sincerely,
Comapany NameFEDERAL REALTY INVESTMENT TRUST
Division of Corporation Finance
May 13, 2021 Page 2 Office of Real Estate & Construction
FirstName LastName