SEC Comment Letter for REV HOLDINGS LLC (CIK 0001035678) — Oct 26, 2005
REV HOLDINGS LLC (CIK 0001035678)
Date: Oct. 26, 2005 · CIK: 0001035678 · Accession: 0000000000-05-054428
AI Filing Summary & Sentiment
File numbers found in text: 333-23451
Letter
Mail Stop 7010 October 26, 2005 Mr. Todd Slotkin REV Holdings LLC 35 East 62nd Street New York, New York 10021
Re: REV Holdings LLC Form 10-K for the year ended December 31, 2004 Filed March 31, 2005 File No. 333-23451
Dear Mr. Slotkin:
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004
Financial Statements for the Year Ended December 31, 2004
Note 1 - Significant Accounting Policies - Principles of Consolidation and Basis of Presentation, page F-7
1. We read that you have consolidated Revlon, Inc. in your financial statements based upon your approximately 51% ownership of the voting power of Revlon, Inc.`s common stock. We also note that you own approximately 14% of the total shares of Revlon, Inc.`s common stock. Please tell us, and revise your consolidation policy in future filings to clarify, why you have not reflected the minority owners` interests in Revlon, Inc. within your financial statements. We assume this is due to the deficit position of the minority interest.
* * *
Please respond to these comments within 10 business days, or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
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 all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosure in their 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
If you have any questions regarding these comments, please direct them to Jennifer Thompson, Staff Accountant, at (202) 551- or, in her absence, to the undersigned at (202) 551-3768.
Sincerely,
John Cash
Accounting Branch Chief
Mr. Todd Slotkin
REV Holdings LLC
October 26, 2005
Page 1
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 7010
October 26, 2005
Mr. Todd Slotkin
REV Holdings LLC
35 East 62nd Street
New York, New York 10021
Re: REV Holdings LLC
Form 10-K for the year ended December 31, 2004
Filed March 31, 2005
File No. 333-23451
Dear Mr. Slotkin:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004
Financial Statements for the Year Ended December 31, 2004
Note 1 - Significant Accounting Policies - Principles of
Consolidation and Basis of Presentation, page F-7
1. We read that you have consolidated Revlon, Inc. in your
financial
statements based upon your approximately 51% ownership of the
voting
power of Revlon, Inc.`s common stock. We also note that you own
approximately 14% of the total shares of Revlon, Inc.`s common
stock.
Please tell us, and revise your consolidation policy in future
filings to clarify, why you have not reflected the minority
owners`
interests in Revlon, Inc. within your financial statements. We
assume this is due to the deficit position of the minority
interest.
* * *
Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response. Please
provide
us with a response letter that keys your responses to our comments
and provides any requested information. Detailed letters greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your responses to our comments.
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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision. Since the company and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their 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.
In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.
If you have any questions regarding these comments, please
direct them to Jennifer Thompson, Staff Accountant, at (202) 551-
3737
or, in her absence, to the undersigned at (202) 551-3768.
Sincerely,
John Cash
Accounting Branch Chief
Mr. Todd Slotkin
REV Holdings LLC
October 26, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>