SEC Comment Letter 0000000000-23-003534 to SBA COMMUNICATIONS CORP (SBAC) (CIK 0001034054) (SBAC)
SBA COMMUNICATIONS CORP (SBAC) (CIK 0001034054)
Date: April 10, 2023 · CIK: 0001034054 · Accession: 0000000000-23-003534
AI Filing Summary & Sentiment
File numbers found in text: 001-16853
Letter
United States securities and exchange commission logo April 10, 2023 Brendan T. Cavanagh Chief Financial Officer SBA Communications Corporation 8051 Congress Avenue Boca Raton, FL 33487 Re:SBA Communications Corporation Form 10-K for fiscal year ended December 31, 2022 Filed March 1, 2023 Form 8-K filed February 21, 2023 File Nos. 001-16853 Dear Brendan T. Cavanagh: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 business days by providing the requested information or advise 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 additional comments. Form 10-K for fiscal year ended December 31, 2022 Consolidated Financial Statements Notes to Consolidated Financial Statements 3. Fair Value Measurements Items Measured at Fair Value on a Nonrecurring Basis, page F-17 1.We note your long-lived and intangible assets are measured at fair value on a nonrecurring basis using Level 3 inputs under a discounted cash flow model. In future periodic filings, please provide quantitative information about the significant unobservable inputs used in the fair value measurement of these assets or tell us why such disclosure is not required. Refer to ASC 820-10-50-2(bbb).
FirstName LastNameBrendan T. Cavanagh Comapany NameSBA Communications Corporation April 10, 2023 Page 2 FirstName LastName Brendan T. Cavanagh SBA Communications Corporation April 10, 2023 Page 2 Form 8-K filed February 21, 2023 Exhibit 99.1 Funds from Operations ("FFO"), Adjusted Funds from Operations ("AFFO"), and AFFO per share, page 15 2.We note your presentation of AFFO per share and the related forecasted guidance. In future earnings releases, please reconcile these non-GAAP financial measures from the the most directly comparable measure calculated in accordance with GAAP. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10(a) of the Division's Non- GAAP Financial Measures Compliance and Disclosure Interpretations. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Isaac Esquivel at (202) 551-3395 or Mark Rakip at (202) 551-3573 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
United States securities and exchange commission logo
April 10, 2023
Brendan T. Cavanagh
Chief Financial Officer
SBA Communications Corporation
8051 Congress Avenue
Boca Raton, FL 33487
Re:SBA Communications Corporation
Form 10-K for fiscal year ended December 31, 2022
Filed March 1, 2023
Form 8-K filed February 21, 2023
File Nos. 001-16853
Dear Brendan T. Cavanagh:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. 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 business days by providing the requested
information or advise 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 additional comments.
Form 10-K for fiscal year ended December 31, 2022
Consolidated Financial Statements
Notes to Consolidated Financial Statements
3. Fair Value Measurements
Items Measured at Fair Value on a Nonrecurring Basis, page F-17
1.We note your long-lived and intangible assets are measured at fair value on a nonrecurring
basis using Level 3 inputs under a discounted cash flow model. In future periodic filings,
please provide quantitative information about the significant unobservable inputs used in
the fair value measurement of these assets or tell us why such disclosure is not required.
Refer to ASC 820-10-50-2(bbb).
FirstName LastNameBrendan T. Cavanagh
Comapany NameSBA Communications Corporation
April 10, 2023 Page 2
FirstName LastName
Brendan T. Cavanagh
SBA Communications Corporation
April 10, 2023
Page 2
Form 8-K filed February 21, 2023
Exhibit 99.1
Funds from Operations ("FFO"), Adjusted Funds from Operations ("AFFO"), and AFFO per
share, page 15
2.We note your presentation of AFFO per share and the related forecasted guidance. In
future earnings releases, please reconcile these non-GAAP financial measures from the
the most directly comparable measure calculated in accordance with GAAP. Refer to
Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10(a) of the Division's Non-
GAAP Financial Measures Compliance and Disclosure Interpretations.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Isaac Esquivel at (202) 551-3395 or Mark Rakip at (202) 551-3573 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction