SEC Comment Letter for RYANAIR HOLDINGS PLC (RYAAY, RYAOF) (CIK 0001038683) (RYAAY) — Mar 30, 2021
RYANAIR HOLDINGS PLC (RYAAY, RYAOF) (CIK 0001038683)
Date: March 30, 2021 · CIK: 0001038683 · Accession: 0000000000-21-003808
AI Filing Summary & Sentiment
File numbers found in text: 000-29304
Letter
United States securities and exchange commission logo March 30, 2021 Neil Sorahan Chief Financial Officer Ryanair Holdings plc c/o Ryanair DAC Dublin Office Airside Business Park, Swords County Dublin, K67 NY94, Ireland Re:Ryanair Holdings plc Form 20-F for Fiscal Year Ended March 31, 2020 July 28, 2020 Form 6-K Filed on February 1, 2021 000-29304 Dear Mr. Sorahan: 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 6-K Filed February 1, 2021 Third Quarter Results for Fiscal Year 2021, page 1 1.Please refer to Regulation G and address the following Non-IFRS issues related to your interim income statement for the 2021 fiscal year:
•Appropriately label your non-IFRS measures. For example, label the Q3 loss of €306 million presented in the heading and first sentence of your earning release as non- IFRS. Similarly, label the appropriate columns of your reconciliation as non-IFRS. •Present the comparable IFRS measure alongside any non-IFRS measures presented. •Present a reconciliation of your non-IFRS measures that begins with the IFRS measure, then adds or subtracts adjustments to arrive at the non-IFRS measures.
FirstName LastNameNeil Sorahan Comapany NameRyanair Holdings plc March 30, 2021 Page 2 FirstName LastName Neil Sorahan Ryanair Holdings plc March 30, 2021 Page 2 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 Yong Kim, Staff Accountant, at (202) 551 - 3323 or Gus Rodriguez, Accounting Branch Chief, at (202) 551 - 3752 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: David I. Gottlieb
Show Raw Text
United States securities and exchange commission logo
March 30, 2021
Neil Sorahan
Chief Financial Officer
Ryanair Holdings plc
c/o Ryanair DAC
Dublin Office
Airside Business Park, Swords
County Dublin, K67 NY94, Ireland
Re:Ryanair Holdings plc
Form 20-F for Fiscal Year Ended March 31, 2020
July 28, 2020
Form 6-K Filed on February 1, 2021
000-29304
Dear Mr. Sorahan:
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 6-K Filed February 1, 2021
Third Quarter Results for Fiscal Year 2021, page 1
1.Please refer to Regulation G and address the following Non-IFRS issues related to your
interim income statement for the 2021 fiscal year:
•Appropriately label your non-IFRS measures. For example, label the Q3 loss of €306
million presented in the heading and first sentence of your earning release as non-
IFRS. Similarly, label the appropriate columns of your reconciliation as non-IFRS.
•Present the comparable IFRS measure alongside any non-IFRS measures presented.
•Present a reconciliation of your non-IFRS measures that begins with the IFRS
measure, then adds or subtracts adjustments to arrive at the non-IFRS measures.
FirstName LastNameNeil Sorahan
Comapany NameRyanair Holdings plc
March 30, 2021 Page 2
FirstName LastName
Neil Sorahan
Ryanair Holdings plc
March 30, 2021
Page 2
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 Yong Kim, Staff Accountant, at (202) 551 - 3323 or Gus Rodriguez,
Accounting Branch Chief, at (202) 551 - 3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: David I. Gottlieb