SEC Comment Letter for SONIDA SENIOR LIVING, INC. (SNDA) (CIK 0001043000) (SNDA) — Dec 22, 2016
SONIDA SENIOR LIVING, INC. (SNDA) (CIK 0001043000)
Date: Dec. 22, 2016 · CIK: 0001043000 · Accession: 0000000000-16-106284
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3720 December 22, 2016 Carey P. Hendrickson Senior 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 Fiscal Year Ended December 31, 2015 Response dated October 12, 2016 File No. 1-13445
Dear Mr. Hendrickson :
We have reviewed your October 12 , 2016 response to our comment letter and have the following comment . Please co mply 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 th e comment 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 comment appli es to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Form 8 -K filed Augus t 2, 2016
Exhibit 99.1
1. We have read your response to comment 2 and we believe that your non -GAAP presentation of EBITDAR that excludes lease expense is inconsistent with Question 100.01 of the updated Non -GAAP Compliance and Disclosure Interpretations issued on May 17, 2016. Please revise in your next earnings release .
You may contact Claire DeLabar, Staff Accountant at (202) 551 -3349 or Terry French, Accountant Branch Chief at (202) 551 -3828 or me at (202) 551 -3810 if you have questions
Carey P. Hendrickson Capital Senior Living Corp. December 22, 2016 Page 2
regarding comments on the financial statements and related matters. Please contact Courtney Lindsay II, Staff Attorney at (202) 551 -7237 or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Terry French for
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Mail Stop 3720 December 22, 2016 Carey P. Hendrickson Senior 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 Fiscal Year Ended December 31, 2015 Response dated October 12, 2016 File No. 1-13445 Dear Mr. Hendrickson : We have reviewed your October 12 , 2016 response to our comment letter and have the following comment . Please co mply 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 th e comment 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 comment appli es to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 8 -K filed Augus t 2, 2016 Exhibit 99.1 1. We have read your response to comment 2 and we believe that your non -GAAP presentation of EBITDAR that excludes lease expense is inconsistent with Question 100.01 of the updated Non -GAAP Compliance and Disclosure Interpretations issued on May 17, 2016. Please revise in your next earnings release . You may contact Claire DeLabar, Staff Accountant at (202) 551 -3349 or Terry French, Accountant Branch Chief at (202) 551 -3828 or me at (202) 551 -3810 if you have questions Carey P. Hendrickson Capital Senior Living Corp. December 22, 2016 Page 2 regarding comments on the financial statements and related matters. Please contact Courtney Lindsay II, Staff Attorney at (202) 551 -7237 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Terry French for Larry Spirgel Assistant Director AD Office 11 – Telecommunications