View:
United States securities and exchange commission logo
November 18, 2022
Marek Bakun
Executive Vice President and Chief Financial Officer
The St. Joe Company
130 Richard Jackson Boulevard , Suite 200
Panama City Beach , FL 32407
Re: The St. Joe Company
Form 10-K for the
year ended December 31, 2022
Form 10-Q for the
quarterly period ended September 30, 2022
File No. 001-10466
Dear Marek Bakun:
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-Q for the quarterly period ended September 30, 2022
Item 2. Management's Discussion and Analysis of Financial Condition and
Results of
Operations, page 49
1. In future filings, both
in the current period and prospectively, please expand your
disclosures to
specifically discuss how increased interest rates impact your results of
operations and your
financial condition.
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 Eric McPhee at 202-551-3693 or Wilson Lee at
202-551-3468 with any
questions.
Marek Bakun
The St. Joe Company
November 18, 2022
Page 2
FirstName LastNameMarek Bakun Sincerely,
Comapany NameThe St. Joe Company
Division of Corporation Finance
November 18, 2022 Page 2 Office of Real Estate & Construction
FirstName LastName