SEC Comment Letter for Strategic Education, Inc. (STRA) (CIK 0001013934) (STRA) — Dec 16, 2011
Strategic Education, Inc. (STRA) (CIK 0001013934)
Date: Dec. 16, 2011 · CIK: 0001013934 · Accession: 0000000000-11-072192
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-21039
Letter
December 16, 2011 Mark C. Brown Chief Financial Officer Strayer Education, Inc. 2303 Dulles Station Boulevard Herndon, VA 20171 Re: Strayer Education, Inc. Form 10-K for the Year Ended December 31, 2010 Filed February 22, 2011 File No. 000-21039
Dear Mr. Brown: We have reviewed your filing and have the following comment. Please respond to this letter within ten business days and indicate that you will comply with our comment in future filings. Confirm in writing that you will do so and also explain to us how you intend to comply. If you do not believe our comment applies to your facts and circumstances or do not believe complia nce in future disclosure is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments.
Management’s Discussion and Analysis, page 46
1. We note disclosure in your Forms 10-Q for the quarters ended March 31, 2011 and June 30, 2011, reflecting a decline in new st udent enrollments, and in the quarter ended September 30, 2011 reflecting a declin e in both new student enrollments and continuing student enrollment. In future filings, please enhance your disclosure to more fully discuss this trend, including ou tlining steps management may take or has taken to address and reverse it, and the e ffect on your results of operations, including revenues and marketing expenses. Please refe r to Item 303(a)(3)( ii) of Regulation S- K.
Mark C. Brown Strayer Education, Inc. Page 2 We urge all persons who are responsible for the accuracy 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 Exchan ge Act rules require. Since the company and its management are in possession of all facts relating to a co mpany’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Please contact Paul Fischer, Staff Atto rney, at 202-551-3415, Celeste M. Murphy, Legal Branch Chief, at 202-551-3257, or me at 202-551-3810 with any questions.
Sincerely,
/s/ Celeste M. Murphy for
Larry Spirgel
A s s i s t a n t D i r e c t o r
Show Raw Text
December 16, 2011
Mark C. Brown Chief Financial Officer Strayer Education, Inc. 2303 Dulles Station Boulevard Herndon, VA 20171
Re: Strayer Education, Inc.
Form 10-K for the Year Ended December 31, 2010 Filed February 22, 2011 File No. 000-21039
Dear Mr. Brown:
We have reviewed your filing and have the following comment.
Please respond to this letter within ten business days and indicate that you will
comply with our comment in future filings. Confirm in writing that you will do so and also explain to us how you intend to comply. If you do not believe our comment applies to your
facts and circumstances or do not believe complia nce in future disclosure is appropriate,
please tell us why in your response.
After reviewing the information you provide in response to this comment, we may
have additional comments.
Management’s Discussion and Analysis, page 46
1. We note disclosure in your Forms 10-Q for the quarters ended March 31, 2011 and
June 30, 2011, reflecting a decline in new st udent enrollments, and in the quarter
ended September 30, 2011 reflecting a declin e in both new student enrollments and
continuing student enrollment. In future filings, please enhance your disclosure to more fully discuss this trend, including ou tlining steps management may take or has
taken to address and reverse it, and the e ffect on your results of operations, including
revenues and marketing expenses. Please refe r to Item 303(a)(3)( ii) of Regulation S-
K.
Mark C. Brown
Strayer Education, Inc. Page 2
We urge all persons who are responsible for the accuracy 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 Exchan ge Act rules require. Since the company and
its management are in possession of all facts relating to a co mpany’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
Please contact Paul Fischer, Staff Atto rney, at 202-551-3415, Celeste M. Murphy,
Legal Branch Chief, at 202-551-3257, or me at 202-551-3810 with any questions.
Sincerely,
/s/ Celeste M. Murphy for
Larry Spirgel
A s s i s t a n t D i r e c t o r