SEC Comment Letter for HOST HOTELS & RESORTS, (HST) — May 14, 2010
HOST HOTELS & RESORTS, INC.
Date: May 14, 2010 · CIK: 0001070750 · Accession: 0000000000-10-027081
AI Filing Summary & Sentiment
Referenced dates: May 3, 2010
Letter
Mail Stop 3010 May 14, 2010 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, 2009 File No. 1-14625
Dear Mr. Harvey:
We have reviewed your first respons e letter dated May 3, 2010 and have the following additional comment. Where indi cated, we think you should revise your document in response to this comment in future filings. If you disagree with a 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, 2009
Proxy Statement on Schedule 14A
Leadership Structure, page 7
1. In future filings, please expand your disc losure to discuss how you determined that your leadership structur e is appropriate given the specific characteristics and circumstances of your business. Please refer to Item 407(h) of Regulation S-K. Please tell us how you intend to comply.
Mr. Harvey Host Hotels & Resorts, Inc. May 14, 2010 Page
As appropriate, please respond to this 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 provides any requested information. Detailed cover letters greatly facilitate our review. Please understa nd that we may have additional comments after reviewin g your response to our comment. You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or Kevin Woody, Branch Chief, at (202) 551-3629 if you have questions regarding comments on the financial statements and related matters . Please contact Stacie Gorman, Staff Attorney, at (202) 551-3585 or me at (202) 551-3233 with regard to legal comments. S i n c e r e l y , Tom Kluck Branch Chief
Show Raw Text
Mail Stop 3010
May 14, 2010
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, 2009
File No. 1-14625
Dear Mr. Harvey:
We have reviewed your first respons e letter dated May 3, 2010 and have the
following additional comment. Where indi cated, we think you should revise your
document in response to this comment in future filings. If you disagree with a 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, 2009
Proxy Statement on Schedule 14A
Leadership Structure, page 7
1. In future filings, please expand your disc losure to discuss how you determined
that your leadership structur e is appropriate given the specific characteristics and
circumstances of your business. Please refer to Item 407(h) of Regulation S-K. Please tell us how you intend to comply.
Mr. Harvey
Host Hotels & Resorts, Inc. May 14, 2010 Page
2
As appropriate, please respond to this 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 provides any requested information.
Detailed cover letters greatly facilitate our review. Please understa nd that we may have
additional comments after reviewin g your response to our comment.
You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or Kevin
Woody, Branch Chief, at (202) 551-3629 if you have questions regarding comments on
the financial statements and related matters . Please contact Stacie Gorman, Staff
Attorney, at (202) 551-3585 or me at (202) 551-3233 with regard to legal comments.
S i n c e r e l y ,
Tom Kluck Branch Chief