SEC Comment Letter for AUTONATION, INC. (AN) (CIK 0000350698) (AN) — Oct 3, 2016
AUTONATION, INC. (AN) (CIK 0000350698)
Date: Oct. 3, 2016 · CIK: 0000350698 · Accession: 0000000000-16-095499
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 September 30 , 2016 Ms. Cheryl Miller Executive Vice President and Chief Financial Officer AutoNation, Inc. 201 SW 1st Avenue Fort Lauderdale, FL 33301
Re: AutoNation, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed February 11, 2016 File No. 1 -13107
Dear Ms. Miller :
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 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.
Selected Financial Data, page 21
1. Your presentatio n of operating income less floorplan interest expense may be inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretations on Non -GAAP Financial Measures issued on May 17, 2016. Please review this guidance w hen preparing your next filing. Also, to the extent that you continue to present this measure, please label it as a non -GAAP.
We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure 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 fa cts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Ms. Cheryl Miller AutoNation, Inc. September 30 , 2016 Page 2
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is respon sible 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 Yong Kim, Staff Accountant, at (202) 551-3323 or me at (202) 551 - 3849 with any questions.
Sincerely,
/s/ James Allegretto
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Mail Stop 3561 September 30 , 2016 Ms. Cheryl Miller Executive Vice President and Chief Financial Officer AutoNation, Inc. 201 SW 1st Avenue Fort Lauderdale, FL 33301 Re: AutoNation, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed February 11, 2016 File No. 1 -13107 Dear Ms. Miller : 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 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. Selected Financial Data, page 21 1. Your presentatio n of operating income less floorplan interest expense may be inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretations on Non -GAAP Financial Measures issued on May 17, 2016. Please review this guidance w hen preparing your next filing. Also, to the extent that you continue to present this measure, please label it as a non -GAAP. We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure 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 fa cts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Ms. Cheryl Miller AutoNation, Inc. September 30 , 2016 Page 2 In responding to our comments, please provide a written statement from the company acknowledging that: the company is respon sible 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 Yong Kim, Staff Accountant, at (202) 551-3323 or me at (202) 551 - 3849 with any questions. Sincerely, /s/ James Allegretto James Allegretto Senior Assistant Chief Accountant Officer of Consumer Products