August 15, 2019
Thomas E. Wirth
Chief Financial Officer
BRANDYWINE REALTY TRUST
2929 Walnut Street
Suite 1700
Philadelphia, PA 19104
Re: BRANDYWINE REALTY TRUST
Form 10-K for the year ended December 31, 2018
Filed February 22, 2019
File No. 001-09106
Dear Mr. Wirth:
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 the year ended December 31, 2018
Financial Statements
Note 3. Real Estate Investments, page F-29
1. With note your disclosure relating to your acquisition of complete
ownership of the Austin
Portfolio. Please tell us how you considered the requirements of Items
2.01 and 9.01)(a)-
(b) of Form 8-K with respect to this acquisition.
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 Jorge Bonilla, Staff Accountant, at (202) 551-3414 or
Daniel Gordon,
Senior Assistant Chief Accountant, at (202) 551-3486 with any questions.
Thomas E. Wirth
BRANDYWINE REALTY TRUST
August 15, 2019
Page 2
Sincerely,
FirstName LastNameThomas E. Wirth
Division of Corporation Finance
Comapany NameBRANDYWINE REALTY TRUST
Office of Real Estate and
August 15, 2019 Page 2 Commodities
FirstName LastName