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PIEDMONT OFFICE REALTY TRUST, INC
VIA EDGAR AND EMAIL
June 2, 2025
Ms. Mary Beth Breslin
Industry Office Chief
Division of Corporation Finance
Office of Real Estate and Construction
U.S. Securities and Exchange Commission
100 F Street, NE
Washington D.C. 20549
Re: Piedmont Office Realty Trust, Inc.
Form 10-K for the year ended December 31, 2024, Filed on February 19, 2025
File No. 001-34626
Dear Ms. Breslin:
This letter is submitted in response to the comments by the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the above referenced filing by Piedmont Office Realty Trust, Inc. (the “Company”). We welcome the opportunity to discuss our response with you, and I am available to do so at (770) 418-8603 or Sherry Rexroad, our Chief Financial Officer, is available at (770) 418-8604.
For your convenience, we have repeated each comment by the Staff immediately preceding our response.
Form 10-K for the year ended December 31, 2024
6. Impairment Charges, page F-23
Comment:
1.Please revise your disclosure to include the goodwill disclosures required by ASC 350-20-50-1 for each of your reportable segments as well as in total.
Response:
We will include in future filings, beginning with our quarterly report on Form 10-Q for the quarter ending June 30, 2025, the following goodwill disclosures required by ASC 350-20-50-1 for each of our reportable segments as well as in total. Presented below for illustrative purposes is a table with information for the years ended December 31, 2024, and 2023 to show an example of the enhanced disclosure approach we intend to take in our future filings:
The change in the carrying amount of Piedmont’s goodwill allocated to each of its reportable segments and in total as of December 31, 2024 and 2023 is as follows (in thousands):
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| Atlanta | | Dallas | | Orlando | | Northern Virginia/
Washington, D.C. | | Minneapolis | | New York | | Boston | | Total |
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| Balance as of January 1, 2023: | | | | | | | | | | | | | | | |
| Goodwill | $ | 18,563 | | | $ | 18,525 | | | $ | 10,818 | | | $ | 15,981 | | | $ | 10,957 | | | $ | 10,585 | | | $ | 13,489 | | | $ | 98,918 | |
| Accumulated impairment charges | — | | | — | | | — | | | (15,981) | | | — | | | — | | | — | | | (15,981) | |
| 18,563 | | | 18,525 | | | 10,818 | | | — | | | 10,957 | | | 10,585 | | | 13,489 | | | 82,937 | |
| | | | | | | | | | | | | | | |
| 2023 impairment charges | — | | | — | | | — | | | — | | | (10,957) | | | (5,000) | | | (13,489) | | | (29,446) | |
| Balance as of December 31, 2023: | | | | | | | | | | | | | | | |
| Goodwill | 18,563 | | | 18,525 | | | 10,818 | | | 15,981 | | | 10,957 | | | 10,585 | | | 13,489 | | | 98,918 | |
| Accumulated impairment charges | — | | | — | | | — | | | (15,981) | | | (10,957) | | | (5,000) | | | (13,489) | | | (45,427) | |
| 18,563 | | | 18,525 | | | 10,818 | | | — | | | — | | | 5,585 | | | — | | | 53,491 | |
| | | | | | | | | | | | | | | |
| 2024 impairment charges | — | | | — | | | — | | | — | | | — | | | — | | | — | | | — | |
| Balance as of December 31, 2024: | | | | | | | | | | | | | | | |
| Goodwill | 18,563 | | | 18,525 | | | 10,818 | | | 15,981 | | | 10,957 | | | 10,585 | | | 13,489 | | | 98,918 | |
| Accumulated impairment charges | — | | | — | | | — | | | (15,981) | | | (10,957) | | | (5,000) | | | (13,489) | | | (45,427) | |
| $ | 18,563 | | | $ | 18,525 | | | $ | 10,818 | | | $ | — | | | $ | — | | | $ | 5,585 | | | $ | — | | | $ | 53,491 | |
Comment:
2.We note your disclosure that you recorded losses for impairment on real estate assets in 2024 and 2022. Please tell us and revise future filings to disclose the segment in which the impaired long-lived asset (asset group) is reported. Refer to ASC 360-10- 50-2(d).
Response:
Our recorded losses for impairment on real estate assets in 2024 and 2022 are related to the following segments:
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| Building | | Reportable Segment | | 2024 | | 2023 | | 2022 |
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| One Lincoln Park | | Dallas | | $ | 932 | | | $ | — | | | $ | — | |
| 750 West John Carpenter Freeway | | Dallas | | 17,500 | | | — | | | — | |
| 80 and 90 Central Street | | Boston | | 10,000 | | | — | | | — | |
161 Corporate Center | | Dallas | | 5,400 | | | — | | | — | |
9320 Excelsior Boulevard | | Minneapolis | | — | | | — | | | 10,000 | |
Total impairment charge on real estate assets | | | | $ | 33,832 | | | $ | — | | | $ | 10,000 | |
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We will include in future filings, beginning with our quarterly report on Form 10-Q for the quarter ending June 30, 2025, disclosure of the reportable segment in which the impaired long-lived asset is reported in accordance with ASC 360-10-50-2(d).
May 28, 2025
Page 2
Sincerely,
/s/ Laura P. Moon
Laura P. Moon
Chief Accounting Officer
Piedmont Office Realty Trust, Inc.
CC: Mr. C. Brent Smith, President, Principal Executive Officer and Director
Ms. Sherry L. Rexroad, Chief Financial Officer, Principal Financial Officer
Mr. Will Herman, Deloitte & Touche LLP
Mr. Keith Townsend, Esq., King & Spalding, LLP