1 EXHIBIT 3.2 Amendment to the Articles of Incorporation of American Realty Trust, Inc. Pursuant to the Unanimous Written Consent of The Board of Directors of American Realty Trust, Inc. (the "Corporation") dated July 21, 1989 and the approval of the shareholders of the Corporation on August 14, 1989, such shareholder approval being in accordance with Section 14-2-1003 of the Georgia Business Corporation Code, the Articles of Incorporation of the Corporation are hereby amended by deleting the first paragraph of Article Five in its entirety and replacing it with the following: The Corporation shall have authority exercisable by its Board of Directors to issue not more than 50,000,000 shares of common voting stock, $2.00 par value per share (the "Common Stock"), and 20,000,000 shares of a special class of stock, $2.00 par value per share (the "Special Stock"), which shall be designated as the Board of Directors may determine and which may be issued in series by the Board of Directors as hereinafter provided. Preferences, limitations, and relative rights with respect to the shares of each class of stock of the Corporation shall be as hereinafter set forth: The foregoing amendment with respect to the Common Stock of the Corporation was approved to effect a one-for-two reverse split of the Corporation's shares of Common Stock, $1.00 par value per share. Such split will be implemented by requiring each holder of shares of Common Stock, $1.00 par value per share, to exchange his or her certificates representing such shares for new certificates representing one share of Common Stock, $2.00 par value per share, on the basis of two shares of Common Stock, $1.00 par value per share, for one share 2 of Common Stock, $2.00 par value per share. Share- holders who would otherwise be entitled to receive fractional shares of Common Stock, $2.00 par value per share, will receive cash in lieu thereof, computed at the average of the mean of the high and low closing prices of the Common Stock, $1.00 par value per share, as reported on the New York Stock Exchange Composite Tape for the 15 trading days immediately preceding the effective date of this Amendment. The foregoing amendment to Article Five shall be effective at the close of business on September 15, 1989. IN WITNESS WHEREOF, I have hereunto set my hand. /s/ William S. Friedman ------------------------------ William S. Friedman Vice President and Treasurer American Realty Trust, Inc.