United States securities and exchange commission logo
May 16, 2022
Mary Doyle
Chief Financial Officer
Great Ajax Corp.
13190 SW 68th Parkway, Suite 110
Tigard, Oregon 97223
Re: Great Ajax Corp.
Form 10-K for the
fiscal year ended December 31, 2021
Filed March 4, 2022
File No. 001-36844
Dear Mary Doyle:
We have limited our review of your filing to the financial
statements and related
disclosures 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, 2021
Notes to Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies
Investments in Beneficial Interests, page F-18
1. We note your accounting
policy for your Investments in Beneficial Interests. Please
address the following:
Please clarify for
us and in your filing how you account for these investments upon
initial
recognition. In this regard, we note your disclosure on page F-31 which states
that that you have
either sponsored or contributed assets to the securitization
trusts. Within your
response and your revised disclosure, please address the
accounting for
situations when you have sponsored the securitization trust and
situations when you
have contributed assets to the securitization trust, if accounting
for such
transactions is different. Please refer to ASC 325-40-30.
We note your tables
on pages F-31 that includes beneficial interests in securitization
Mary Doyle
Great Ajax Corp.
May 16, 2022
Page 2
trusts within your total investments at fair value. Please
clarify for us and in your
filing if the investments in beneficial interests are
subsequently measured at fair value
or at some other value. Please refer to ASC 325-40-35.
To the extent you record these investments at fair value,
please tell us how you
determined it was unnecessary to provide quantitative information
about the
significant unobservable inputs used in the fair value
measurement of these
investments. Please refer to ASC 820-10-50-2(bbb).
In closing, 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 Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-
3295 with any questions.
FirstName LastNameMary Doyle Sincerely,
Comapany NameGreat Ajax Corp.
Division of
Corporation Finance
May 16, 2022 Page 2 Office of Real
Estate & Construction
FirstName LastName