Published on November 18, 2020
United States securities and exchange commission logo
November 18, 2020
Thomas O'Malley
Chief Financial Officer
Global Self Storage, Inc.
11 Hanover Square
New York, NY 10005
Re: Global Self
Storage, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed March 30,
2020
File No. 001-12681
Dear Mr. O'Malley:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Item 15. Exhibits, Financial Statement Schedules, page 49
1. The certifications
filed as Exhibits 31.1 and 31.2 do not include the introductory language
in paragraph 4 and
paragraph 4(b) referring to internal control over financial
reporting. Please file
an amendment to your Form 10-K to include the certifications
exactly as set forth in
Item 601(b)(31) of Regulation S-K. The amendment should
include updated and
corrected Section 302 certifications, Section 906 certifications, full
Item 9A disclosure and
your audited financial statements. Refer to Regulation S-K
Compliance & Disclosure
Interpretation 246.13.
Schedule III Real Estate and Related Depreciation, page F-21
2. Please tell us how you
complied with footnote 6 to Rule 12-28 of Regulation S-X, or tell
us how you determined
it was not necessary to disclose the aggregate cost of your real
estate assets for
Federal income tax purposes.
Thomas O'Malley
Global Self Storage, Inc.
November 18, 2020
Page 2
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 Isaac Esquivel at (202) 551-3395 or Kristi Marrone at
(202) 551-3429
with any questions.
FirstName LastNameThomas O'Malley Sincerely,
Comapany NameGlobal Self Storage, Inc.
Division of
Corporation Finance
November 18, 2020 Page 2 Office of Real Estate
& Construction
FirstName LastName