SEC Company Response from ALLIANCEBERNSTEIN HOLDING L.P. (AB) (CIK 0000825313) (AB) — Mar 30, 2020
ALLIANCEBERNSTEIN HOLDING L.P. (AB) (CIK 0000825313)
Date: March 30, 2020 · CIK: 0000825313 · Accession: 0000825313-20-000021
AI Filing Summary & Sentiment
File numbers found in text: 001-09818
Referenced dates: March 19, 2020
Letter
United States Securities and Exchange Commission Division of Corporate Finance Re: AllianceBernstein Holding L.P. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 12, 2020 File No. 001-09818
Dear Mr. Klein:
We are responding to your comment letter dated March 19, 2020 regarding the Form 10-K (“2019 Form 10-K”) filed February 12, 2020 by AllianceBernstein Holding L.P. (“AB Holding”).
In order to expedite your review, we have repeated (in bold) your comments and set forth our response directly below the comment.
Form 10-K filed February 12, 2020
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Management Operating Metrics, page 46
1.
We note your disclosure on page 47 showing an adjustment for distribution-related payments to calculate Adjusted Net Revenues and Adjusted Operating Margin. In future filings, please revise to adjust by distribution revenues, rather than expenses, and provide supplemental information (e.g., footnote(s) to your reconciliation) to clearly explain each adjustment. To the extent that these distribution revenues are recognized in multiple revenue line items on the face of the income statement, disaggregate and distinguish the adjustment into multiple components in the related non-GAAP reconciliation. In addition, and if applicable, in periods when a material amount of fee waivers or other material non-standard items impact distribution revenues, provide disclosure quantifying the impact that it has or could have upon Adjusted Operating Margin, or any equivalent.
Response:
In our first quarter 2020 Form 10-Q and all future filings, we will revise our non-GAAP revenue reconciliation to adjust by distribution revenues, rather than expenses, and provide supplemental information (e.g., footnote(s) to our reconciliation) to clearly explain each adjustment. To the extent that these distribution revenues are recognized in multiple revenue line items on the face of the income statement, we will disaggregate and distinguish the adjustment into multiple components in the related non-GAAP reconciliation. In addition, in periods when a material amount of fee waivers or other material non-standard items impact distribution revenues, we will provide disclosure quantifying the impact that it has upon Adjusted Operating Margin; presently, we have no such non-standard items.
* * * *
AB Holding acknowledges that it is responsible for the adequacy and accuracy of their disclosures, notwithstanding any review, comments, actions or absence of action by the staff.
If you have any questions, please do not hesitate to contact me at (212) 823-3023.
Sincerely,
/s/ John C. Weisenseel
Show Raw Text
CORRESP 1 filename1.htm Document One Nashville Place 150 4th Ave N, Floor 16 Nashville TN, 37219 www.AllianceBernstein.com March 30, 2020 By EDGAR Mr. Robert Klein Staff Accountant United States Securities and Exchange Commission Division of Corporate Finance 100 F. Street, N.E. Washington, D.C. 20549 Re: AllianceBernstein Holding L.P. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 12, 2020 File No. 001-09818 Dear Mr. Klein: We are responding to your comment letter dated March 19, 2020 regarding the Form 10-K (“2019 Form 10-K”) filed February 12, 2020 by AllianceBernstein Holding L.P. (“AB Holding”). In order to expedite your review, we have repeated (in bold) your comments and set forth our response directly below the comment. Form 10-K filed February 12, 2020 Management’s Discussion and Analysis of Financial Condition and Results of Operations Management Operating Metrics, page 46 1. We note your disclosure on page 47 showing an adjustment for distribution-related payments to calculate Adjusted Net Revenues and Adjusted Operating Margin. In future filings, please revise to adjust by distribution revenues, rather than expenses, and provide supplemental information (e.g., footnote(s) to your reconciliation) to clearly explain each adjustment. To the extent that these distribution revenues are recognized in multiple revenue line items on the face of the income statement, disaggregate and distinguish the adjustment into multiple components in the related non-GAAP reconciliation. In addition, and if applicable, in periods when a material amount of fee waivers or other material non-standard items impact distribution revenues, provide disclosure quantifying the impact that it has or could have upon Adjusted Operating Margin, or any equivalent. Response: In our first quarter 2020 Form 10-Q and all future filings, we will revise our non-GAAP revenue reconciliation to adjust by distribution revenues, rather than expenses, and provide supplemental information (e.g., footnote(s) to our reconciliation) to clearly explain each adjustment. To the extent that these distribution revenues are recognized in multiple revenue line items on the face of the income statement, we will disaggregate and distinguish the adjustment into multiple components in the related non-GAAP reconciliation. In addition, in periods when a material amount of fee waivers or other material non-standard items impact distribution revenues, we will provide disclosure quantifying the impact that it has upon Adjusted Operating Margin; presently, we have no such non-standard items. * * * * AB Holding acknowledges that it is responsible for the adequacy and accuracy of their disclosures, notwithstanding any review, comments, actions or absence of action by the staff. If you have any questions, please do not hesitate to contact me at (212) 823-3023. Sincerely, /s/ John C. Weisenseel ________________________________ John C. Weisenseel Chief Financial Officer AllianceBernstein Holding L.P.