SEC Comment Letter for American Airlines Group (AAL) — Sep 29, 2016
American Airlines Group Inc.
Date: Sept. 29, 2016 · CIK: 0000006201 · Accession: 0000000000-16-095123
AI Filing Summary & Sentiment
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September 28 , 2016 Derek J. Kerr Chief Financial Officer American Airlines Group, Inc. 4333 Amon Carter Blvd. Fort Worth, Texas 76155 Re: American Airlines Group, Inc. Form 8-K dated July 22, 2016 Filed July 22, 2016 File No. 001 -08400 Dear Mr. Kerr : We have limited our review of your filing to those issues w e have addressed in our 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 busine ss days by providing the requested information or advis e 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. Exhibit 99.1 Reconciliation of Non -GAAP Financial Information , page 11 1. Given the similarity in types of operating speci al items related to your non -GAAP measures described in footnote (1) , please tell us why you have only calculated the net tax effect of special items for 2016 ($50 million). We urge all persons who are responsible for the accuracy and adequacy of the disc losure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disc losure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: Derek J. Kerr American Airlines Group, Inc. September 28 , 2016 Page 2 the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Amy Geddes at 202 -551-3304 or Lyn Shenk at 202 -551-3380 with any questi ons related to these comments. You may also contact me at 202 -551-3377. Sincerely, /s/ Andrew Mew Andrew Mew Senior Assistant Chief Accountant Office of Transportation and Leisure