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On December 9, 2008, the staff at the SEC (the "Staff") released their Financial Reporting Manual which includes the recent changes in reporting for acquisitions by blind pool non-exchange traded REITs summarized in our May 29, 2008 REIT Alert "SEC Seeks Improved Disclosure by Non-Exchange Traded REITs."¹ In short, the revised guidance requires non-exchange traded REITs to file financial statements that satisfy the requirements of Rule 3-14 for acquisitions made during the distribution period if these acquisitions represent 10% or more of their total assets as of the date of acquisition. Non-exchange traded REITs must file these financial statements no later than 71 calendar days after...

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