SEC Comment Letter for HOST HOTELS & RESORTS, (HST) — Apr 21, 2009
HOST HOTELS & RESORTS, INC.
Date: April 21, 2009 · CIK: 0001070750 · Accession: 0000000000-09-020967
AI Filing Summary & Sentiment
File numbers found in text: 001-14625
Letter
Mail Stop 4561 April 22, 2009 Mr. Larry K. Harvey Chief Financial Officer Host Hotels & Resorts, Inc. 6903 Rockledge Drive, Suite 1500 Bethesda, Maryland 20817
Re: Host Hotels & Resorts, Inc. Form 10-K for the year ended December 31, 2008 File No. 001-14625
Dear Mr. Harvey:
We have reviewed your response letter filed on April 15, 2009 and have the following comment. Where indicated, we th ink you should revise your document in future filings in response to our comment. If you disagree with our comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. In our comment, 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.
Form 10-K for the year ended December 31, 2008
Management’s Discussion and Analysis of Re sults of Operations and Financial Condition
Critical Accounting Policies
Impairment Testing, page 68
1. We note your response to our prior co mment. Please confirm that you will enhance your disclosure of critical accounting estimates and assumptions related to your impairment testing in future fi lings to include similar information as presented in your response. Within your di sclosure, please incl ude a discussion of the susceptibility of your critical accounting estimates and assumptions to change. Additionally, please disclose the change in the cash fl ow growth rate assumption
Mr. Harvey Host Hotels & Resorts, Inc. April 22, 2009 Page
that would result in an impairment charge being recorded. Las tly, your disclosure should specifically address the assumptions that you will use for estimating expected useful property lives for those pr operties that are approaching the end of their GAAP depreciable lives. Reference is made to Staff Release No. 33-8350.
As appropriate, please respond to our comm ent within 10 business days or tell us when you will provide us with a response. Please submit a response letter on EDGAR that keys your response to our comment and provide any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact Howard Ef ron, Staff Accountant, at (202) 551-3439 or me at (202) 551-3629 if you have questions regard ing comments on the financial statements and related matters.
S i n c e r e l y ,
Kevin Woody Branch Chief
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Mail Stop 4561
April 22, 2009
Mr. Larry K. Harvey Chief Financial Officer Host Hotels & Resorts, Inc. 6903 Rockledge Drive, Suite 1500 Bethesda, Maryland 20817
Re: Host Hotels & Resorts, Inc.
Form 10-K for the year ended December 31, 2008
File No. 001-14625
Dear Mr. Harvey:
We have reviewed your response letter filed on April 15, 2009 and have the
following comment. Where indicated, we th ink you should revise your document in
future filings in response to our comment. If you disagree with our comment, we will
consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. In our comment, 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.
Form 10-K for the year ended December 31, 2008
Management’s Discussion and Analysis of Re sults of Operations and Financial Condition
Critical Accounting Policies
Impairment Testing, page 68
1. We note your response to our prior co mment. Please confirm that you will
enhance your disclosure of critical accounting estimates and assumptions related to your impairment testing in future fi lings to include similar information as
presented in your response. Within your di sclosure, please incl ude a discussion of
the susceptibility of your critical accounting estimates and assumptions to change. Additionally, please disclose the change in the cash fl ow growth rate assumption
Mr. Harvey
Host Hotels & Resorts, Inc. April 22, 2009 Page
2
that would result in an impairment charge being recorded. Las tly, your disclosure
should specifically address the assumptions that you will use for estimating expected useful property lives for those pr operties that are approaching the end of
their GAAP depreciable lives. Reference is made to Staff Release No. 33-8350.
As appropriate, please respond to our comm ent within 10 business days or tell us
when you will provide us with a response. Please submit a response letter on EDGAR that keys your response to our comment and provide any requested information. Detailed
cover letters greatly facilitate our review. Please understand that we may have additional
comments after reviewing your response to our comment.
You may contact Howard Ef ron, Staff Accountant, at (202) 551-3439 or me at
(202) 551-3629 if you have questions regard ing comments on the financial statements
and related matters.
S i n c e r e l y ,
Kevin Woody Branch Chief