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
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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