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6711 Columbia Gateway Drive, Suite 300 |
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Columbia, Maryland 21046-2104 | |
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Telephone 443-285-5400 | |
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Facsimile 443-285-7650 | |
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www.copt.com | |
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NYSE: OFC |
Ms. Jaime G. John
Accounting Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
July 31, 2015
Re: Corporate Office Properties Trust
Form 10-K for the fiscal year ended December 31, 2014
Filed February 18, 2015
File No. 1-14023
Corporate Office Properties, L.P.
Form 10-K for the fiscal year ended December 31, 2014
Filed February 18, 2015
File No. 333-189188
Dear Ms. John:
Corporate Office Properties Trust (“COPT”) and Corporate Office Properties, L.P. (“COPLP”) are writing in response to the letter dated July 21, 2015 received from the Staff of the Securities and Exchange Commission (the “Commission”) regarding COPT’s and COPLP’s Annual Reports on Form 10-K for the year ended December 31, 2014 (the “2014 Form 10-K” or the “filing”). Our responses to the Staff’s comments appearing in the letter are set forth below. For reference, the Staff’s comments, set forth in bold font, precede the Company’s responses.
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Funds from Operations, page 50
1. Given that you indicate that Basic FFO represents FFO available to common share and common unit holders, in future periodic filings revise Basic and Diluted FFO in your reconciliation on page 52 to clearly label this measure.
Response: We will clearly label those measures in future filings.
Item 8. Financial Statements and Supplementary Data
Note 17 — Operating Leases, page F-47
2. We note your disclosure on page 34 that the majority of your leases with the United States Government consist of a series of one-year renewal options or provide for early termination rights. Please tell us how these leases are reflected in your table on page F-47 of gross minimum future rentals on noncancelable leases and tell us the percentage of each amount in the table that includes such leases.
Response: Our disclosure of gross minimum future rentals in the table on page F-47 includes rents from our leases with the United States Government when we conclude that the exercise of these renewal options is reasonably assured. Rents from these leases comprise the following percentages of each amount in the table:
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2015 |
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18% |
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2016 |
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19% |
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2017 |
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20% |
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2018 |
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18% |
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2019 |
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19% |
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Thereafter |
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27% |