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SEC Comment Letter for HOST HOTELS & RESORTS, (HST) — May 12, 2017

HOST HOTELS & RESORTS, INC.
Date: May 12, 2017 · CIK: 0001070750 · Accession: 0000000000-17-016802

Financial Reporting Business Model Clarity Regulatory Compliance

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
May 12, 2017
Author
/s/ Robert F. Telewicz, Jr.
Form
UPLOAD
Company
HOST HOTELS & RESORTS, INC.

Letter

Mailstop 3233 May 12, 201 7 Via E-mail Mr. Gregory J. Larson Chief Financial Officer Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P. 6903 Rockledge Drive, Suite 1500 Bethesda, MD, 20817

Re: Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P. Form 10-K for the fiscal year e nded December 31, 201 6 Filed February 24, 201 7 File No. 001 -14625 (Host Inc.) File No. 333 -55807 (Host L.P.)

Dear Mr. Larson :

We have reviewed your April 2 4, 2017 r esponse to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to these comments within ten business days b y providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments , we may have additional comments . Unless we note otherwise, our references to prior comments are to comments in our April 19, 2017 letter.

Mr. Gregory J. Larson Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P. May 12, 201 7 Page 2

Form 10 -K for the fiscal year ended December 31, 2016

Item 8. Financial Statements and Supplementary Data

15. Geographic and Business Segment Information, page 128

We have considered your response to our prior comment two. Please elaborate on how you determined your operating segments meet the aggregation criteria of ASC Topic 280 -10-50-11 to be aggregated into one reportable segment. In your response please address the following:

 Please expand on your determination that all of your hotels share similar economic characteristics. In your response, please address the fact that average room rate and revenue per available room appears to vary by property type as disclosed in your earnings release.  Please elaborate on how you concluded all of your properties offer similar products and services and serve a similar type or class of customer. Your response shoul d address how these criteria are similar among each property type (Urban, Suburban, Resort and Airport). For example, please explain to us how determined your resort properties serve a similar type or class of customer as your urban or airport properties.

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.

You may contact Jeffrey Lewis, Staff Accountant, at (202) 551 -6216 or the undersigned at (202) 551 -3438 with any questions.

Sincerely,
/s/ Robert F. Telewicz, Jr.

Show Raw Text
Mailstop 3233
May 12, 201 7

Via E-mail
Mr. Gregory J. Larson
Chief Financial Officer
Host Hotels & Resorts, Inc.
Host Hotels & Resorts, L.P.
6903 Rockledge Drive, Suite 1500
Bethesda,  MD, 20817

Re: Host Hotels & Resorts, Inc.
Host Hotels & Resorts, L.P.
 Form 10-K for the  fiscal  year e nded December 31, 201 6
Filed February  24, 201 7
File No. 001 -14625 (Host Inc.)
File No. 333 -55807 (Host L.P.)

Dear Mr. Larson :

We have reviewed your April 2 4, 2017 r esponse to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.

Please respond to these comments within ten business days b y providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments , we may have additional comments .
Unless we note otherwise, our references to prior comments are to comments in our April 19,
2017 letter.

Mr. Gregory J. Larson
Host Hotels & Resorts, Inc.
Host Hotels & Resorts, L.P.
May 12, 201 7
Page 2

 Form 10 -K for the fiscal year ended December 31, 2016

Item 8. Financial Statements and Supplementary Data

15. Geographic and Business Segment Information, page 128

We have considered your response to our prior comment two.  Please elaborate on how you
determined your operating segments meet the aggregation criteria of ASC Topic 280 -10-50-11 to
be aggregated  into one reportable segment.  In your response please address the following:

 Please expand on your determination that all of your hotels share similar economic
characteristics.  In your response, please address the fact that average room rate and
revenue  per available room appears to vary by property type as disclosed in your
earnings release.
 Please elaborate on how you concluded all of your properties offer similar products and
services and serve a similar type or class of customer.  Your response shoul d address
how these criteria are similar among each property type (Urban, Suburban, Resort and
Airport).  For example, please explain to us how determined your resort properties serve
a similar type or class of customer as your urban or airport properties.

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.

You may contact Jeffrey Lewis, Staff Accountant, at (202) 551 -6216 or the undersigned
at (202) 551 -3438 with any questions.

Sincerely,

/s/ Robert F. Telewicz, Jr.

Robert F. Telewicz, Jr.
Accounting Branch Chief
Office of Real Estate and
Commodities