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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

Financial Reporting Regulatory Compliance Revenue Recognition

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
July 22, 2016
Author
/s/ Andrew Mew
Form
UPLOAD
Company
American Airlines Group Inc.

Letter

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

Show Raw Text
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