SEC Comment Letter for HOST HOTELS & RESORTS, (HST) — Jul 13, 2017
HOST HOTELS & RESORTS, INC.
Date: July 13, 2017 · CIK: 0001070750 · Accession: 0000000000-17-024588
AI Filing Summary & Sentiment
Letter
Mailstop 3233 July 13, 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 June 9 , 2017 response 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 by 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 r esponse.
After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comme nts are to comments in our May 12, 2017 letter.
Mr. Gregory J. Larson Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P. July 13, 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
1. We note your response to our prior comment one and that despite the dispersion in room rates and in RevPAR levels between properties in di fferent locations or property types (Urban, Suburban, Resort and Airport) , you believe that your hotels share similar economic characteristics. Please clarify if your chief operating decision maker relies on certain performance measures (i.e. operating ma rgin, net income, EBITDA, etc.) to evaluate the operating performance of your hotels and if such measures are evaluated in the determination that all of your hotels share similar economic characteristics.
We remind you that the company and its managemen t 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.
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Mailstop 3233 July 13, 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 June 9 , 2017 response 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 by 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 r esponse. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comme nts are to comments in our May 12, 2017 letter. Mr. Gregory J. Larson Host Hotels & Resorts, Inc. Host Hotels & Resorts, L.P. July 13, 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 1. We note your response to our prior comment one and that despite the dispersion in room rates and in RevPAR levels between properties in di fferent locations or property types (Urban, Suburban, Resort and Airport) , you believe that your hotels share similar economic characteristics. Please clarify if your chief operating decision maker relies on certain performance measures (i.e. operating ma rgin, net income, EBITDA, etc.) to evaluate the operating performance of your hotels and if such measures are evaluated in the determination that all of your hotels share similar economic characteristics. We remind you that the company and its managemen t 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