October 3, 2019
Thomas E. O'Hern
Chief Executive Officer
MACERICH CO
401 Wilshire Boulevard. Suite 700
Santa Monica, CA 90401
Re: MACERICH CO
Form 10-K for the fiscal year ended December 31, 2018
Filed February 25, 2019
Form 10-Q for the quarterly period ended June 30, 2019
Filed August 5, 2019
File No. 001-12504
Dear Mr. O'Hern:
We have reviewed your September 27, 2019 response to our comment letter
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. Unless we note otherwise, our references to prior comments are to
comments in our
September 12, 2019 letter.
Form 10-Q for the quarterly period ended June 30, 2019
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Funds from Operations ("FFO"), page 42
1. We note your response to comment 1 of our letter dated September 12,
2019. We are
unclear how your exclusion of the Chandler Freehold financing expense is
consistent with
the commonly understood industry definition of FFO. Please revise future
filings to retitle
the measure or remove the related adjustment.
You may contact Jorge Bonilla, Staff Accountant, at (202) 551-3414 or
Jennifer Monick,
Assistant Chief Accountant, at (202) 551-3295 if you have any questions.
Thomas E. O'Hern
MACERICH CO
October 3, 2019
Page 2
FirstName LastNameThomas E. O'Hern Sincerely,
Comapany NameMACERICH CO
Division of Corporation Finance
October 3, 2019 Page 2 Office of Real Estate & Construction
FirstName LastName