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SEC Comment Letter 0000000000-24-005327 to CUMULUS MEDIA INC (CMLS) (CIK 0001058623) (CMLS)

CUMULUS MEDIA INC (CMLS) (CIK 0001058623)
Date: May 10, 2024 · CIK: 0001058623 · Accession: 0000000000-24-005327

AI Filing Summary & Sentiment

File numbers found in text: 001-38108

Date
May 10, 2024
Author
Office of Technology
Form
UPLOAD
Company
CUMULUS MEDIA INC (CMLS) (CIK 0001058623)

Letter

United States securities and exchange commission logo May 10, 2024 Frank Lopez-Balboa Chief Financial Officer Cumulus Media, Inc. 780 Johnson Ferry Road NE, Suite 500 Atlanta, GA 30342 Re:Cumulus Media, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-38108 Dear Frank Lopez-Balboa: We have reviewed your filing and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2023 Notes to Consolidated Financial Statements 1. Nature of Business, Basis of Presentation and Summary of Significant Accounting Policies Revenue Recognition, page F-9 1.We note your statement on page F-8 that "Cumulus Media is the only audio media company to provide marketers with local and national advertising performance guarantees." Please expand you revenue recognition disclosure to discuss how you account for advertising performance guarantees. Specifically discuss if revenue recognition is deferred until the performance guarantees are met. 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.

FirstName LastNameFrank Lopez-Balboa Comapany NameCumulus Media, Inc. May 10, 2024 Page 2 FirstName LastName Frank Lopez-Balboa Cumulus Media, Inc. May 10, 2024 Page 2 Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology

Show Raw Text
United States securities and exchange commission logo
May 10, 2024
Frank Lopez-Balboa
Chief Financial Officer
Cumulus Media, Inc.
780 Johnson Ferry Road NE, Suite 500
Atlanta, GA 30342
Re:Cumulus Media, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-38108
Dear Frank Lopez-Balboa:
            We have reviewed your filing and have the following comment.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
1. Nature of Business, Basis of Presentation and Summary of Significant Accounting Policies
Revenue Recognition, page F-9
1.We note your statement on page F-8 that "Cumulus Media is the only audio media
company to provide marketers with local and national advertising performance
guarantees."  Please expand you revenue recognition disclosure to discuss how you
account for advertising performance guarantees. Specifically discuss if revenue
recognition is deferred until the performance guarantees are met.
            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.

 FirstName LastNameFrank Lopez-Balboa
 Comapany NameCumulus Media, Inc.
 May 10, 2024 Page 2
 FirstName LastName
Frank Lopez-Balboa
Cumulus Media, Inc.
May 10, 2024
Page 2
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology