SEC Comment Letter for SONIDA SENIOR LIVING, INC. (SNDA) (CIK 0001043000) (SNDA) — Dec 6, 2013
SONIDA SENIOR LIVING, INC. (SNDA) (CIK 0001043000)
Date: Dec. 6, 2013 · CIK: 0001043000 · Accession: 0000000000-13-066678
AI Filing Summary & Sentiment
Reasoning
Referenced dates: November 20, 2013
Letter
December 6, 2013 Via E -mail Mr. Ralph A. Beattie Executive Vice President and Chief Financial Officer Capital Senior Living Corporation 14160 Dallas Parkway, Suite 300 Dallas, TX 75254
Re: Capital Senior Living Corporation Form 10 -K for the Year Ended December 31, 2012 Filed March 8, 2013 Form 8 -K dated November 4, 2013 Filed November 4, 2013 Response dated December 3, 2013 File No. 1-13445
Dear Mr. Beattie :
We have reviewed your response letter and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply .
Please respond to this letter within ten busines s days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing the informatio n you provide in response to this comment, we may have additional comments.
Form 8 -K dated November 4, 2013
1. We note your response to comment three from our letter dated November 20, 2013. Please tell us how you will revise future press releases to addr ess the undue prominence of your discussion focused on the non -GAAP measures and references to Adjusted Cash From Facility Operations (CFFO), Adjusted EBITDAR, and EBITDAR margin in the introduction of the earnings release. Please note that Item 10(e) requ ires the presentation, with equal or greater prominence, of the corresponding most directly comparable GAAP measures.
Ralph A. Beattie Capital Senior Living Corporation December 6, 2013 Page 2
You may contact Claire DeLabar , Senior Staff Accountant, at (202) 551 -3349 or Terry French, Accountant Branch Chief, at (202) 551 -3828 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp, Attorney - Advisor, at (202) 551 -6971 or Kathleen Krebs, Special Counsel , at (202) 551 -3350 or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Terry French for
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December 6, 2013 Via E -mail Mr. Ralph A. Beattie Executive Vice President and Chief Financial Officer Capital Senior Living Corporation 14160 Dallas Parkway, Suite 300 Dallas, TX 75254 Re: Capital Senior Living Corporation Form 10 -K for the Year Ended December 31, 2012 Filed March 8, 2013 Form 8 -K dated November 4, 2013 Filed November 4, 2013 Response dated December 3, 2013 File No. 1-13445 Dear Mr. Beattie : We have reviewed your response letter and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply . Please respond to this letter within ten busines s days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing the informatio n you provide in response to this comment, we may have additional comments. Form 8 -K dated November 4, 2013 1. We note your response to comment three from our letter dated November 20, 2013. Please tell us how you will revise future press releases to addr ess the undue prominence of your discussion focused on the non -GAAP measures and references to Adjusted Cash From Facility Operations (CFFO), Adjusted EBITDAR, and EBITDAR margin in the introduction of the earnings release. Please note that Item 10(e) requ ires the presentation, with equal or greater prominence, of the corresponding most directly comparable GAAP measures. Ralph A. Beattie Capital Senior Living Corporation December 6, 2013 Page 2 You may contact Claire DeLabar , Senior Staff Accountant, at (202) 551 -3349 or Terry French, Accountant Branch Chief, at (202) 551 -3828 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp, Attorney - Advisor, at (202) 551 -6971 or Kathleen Krebs, Special Counsel , at (202) 551 -3350 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Terry French for Larry Spir gel Assistant Director