SEC Comment Letter for IRON MOUNTAIN INC (IRM) (CIK 0001020569) (IRM) — Aug 8, 2017
IRON MOUNTAIN INC (IRM) (CIK 0001020569)
Date: Aug. 8, 2017 · CIK: 0001020569 · Accession: 0000000000-17-028018
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13045
Letter
Mailstop 3233 August 8 , 2017 Via E -Mail Stuart B. Brown Executive Vice President and Chief Financial Officer Iron Mountain Incorporated One Federal Street Boston, MA 02110
Re: Iron Mountain Incorporated Form 10 -K for the fiscal year ended December 31, 2016 Filed February 23, 2017 Form 10 -Q for the interim period ended June 30, 201 7 Filed July 28 , 2017 File No. 001-13045
Dear Mr. Brown:
We have reviewed your July 26, 2017 response to our comment letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have a dditional comments. Unless we note otherwise, our references to prior comments are to c omments in our July 14, 2017 letter .
Form 10 -K for the fiscal year ended December 31, 2016
Item 2. Properties, page 26 1. We note your response to prior comment 1. Pl ease con sider disclos ing Total Building Utilization and Total Racking Utilization on a disaggregated basis by geographic area , thereby furnishing investors greater visibility into the impact of storage rental leasing trends within your portfolio or tell us why you believe such disclosure would not be meaningful to investors .
Stuart B. Brown Iron Mountain Incorporated August 8, 2017 Page 2
Schedule III – Schedule of Real Estate and Accumulated Depreciation, page 159 2. We note your response to prior comment 4. Given the significance of the reconciling items, please confirm that they will be quantified as part of your proposed disclosure.
Form 10 -Q for the interim period ended June 30, 2017
(10) Divestments, page 47 3. We no te on May 30, 2017 your records and information management operations in Russia and Ukraine were sold to OSG Rec ords Management (Europe) Limited for a 25% interest in OSG. Please address the following: a. clarify how you determined the amount of gain on sale recognized, given the $39.8 million gain exceeded the fair value of the consideration received which you indicate was $18 million, and provide an analysis of the accounting guidance relied upon when making this determination ; b. tell us how you calculated th e $18 million fair value of the 25% interest in OSG received in consideration for such sale; and c. detail whether any such gain on sale was deferred and the basis of your conclusion, including the accounting guidance relied upon .
You may contact Mark Rakip , Staff Accountant at 202.551.3573 or me at 202.551.3429 if you have questions regarding comments on the financial statements and related matters
Sincerely,
/s/ Kristi Marrone
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Mailstop 3233 August 8 , 2017 Via E -Mail Stuart B. Brown Executive Vice President and Chief Financial Officer Iron Mountain Incorporated One Federal Street Boston, MA 02110 Re: Iron Mountain Incorporated Form 10 -K for the fiscal year ended December 31, 2016 Filed February 23, 2017 Form 10 -Q for the interim period ended June 30, 201 7 Filed July 28 , 2017 File No. 001-13045 Dear Mr. Brown: We have reviewed your July 26, 2017 response to our comment letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have a dditional comments. Unless we note otherwise, our references to prior comments are to c omments in our July 14, 2017 letter . Form 10 -K for the fiscal year ended December 31, 2016 Item 2. Properties, page 26 1. We note your response to prior comment 1. Pl ease con sider disclos ing Total Building Utilization and Total Racking Utilization on a disaggregated basis by geographic area , thereby furnishing investors greater visibility into the impact of storage rental leasing trends within your portfolio or tell us why you believe such disclosure would not be meaningful to investors . Stuart B. Brown Iron Mountain Incorporated August 8, 2017 Page 2 Schedule III – Schedule of Real Estate and Accumulated Depreciation, page 159 2. We note your response to prior comment 4. Given the significance of the reconciling items, please confirm that they will be quantified as part of your proposed disclosure. Form 10 -Q for the interim period ended June 30, 2017 (10) Divestments, page 47 3. We no te on May 30, 2017 your records and information management operations in Russia and Ukraine were sold to OSG Rec ords Management (Europe) Limited for a 25% interest in OSG. Please address the following: a. clarify how you determined the amount of gain on sale recognized, given the $39.8 million gain exceeded the fair value of the consideration received which you indicate was $18 million, and provide an analysis of the accounting guidance relied upon when making this determination ; b. tell us how you calculated th e $18 million fair value of the 25% interest in OSG received in consideration for such sale; and c. detail whether any such gain on sale was deferred and the basis of your conclusion, including the accounting guidance relied upon . You may contact Mark Rakip , Staff Accountant at 202.551.3573 or me at 202.551.3429 if you have questions regarding comments on the financial statements and related matters Sincerely, /s/ Kristi Marrone Kristi Marrone Staff Accountant Office of Real Estate and Commodities