SEC Comment Letter 0000000000-23-005411 to CoreCivic, Inc. (CXW) (CIK 0001070985) (CXW)
CoreCivic, Inc. (CXW) (CIK 0001070985)
Date: May 22, 2023 · CIK: 0001070985 · Accession: 0000000000-23-005411
AI Filing Summary & Sentiment
File numbers found in text: 001-16109
Letter
United States securities and exchange commission logo May 22, 2023 David M. Garfinkle Executive Vice President and Chief Financial Officer CoreCivic, Inc. 5501 Virginia Way Brentwood, TN 37027 Re:CoreCivic, Inc. Form 10-K for fiscal year ended December 31, 2022 Filed February 21, 2023 File No. 001-16109 Dear David M. Garfinkle: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for fiscal year ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies and Estimates Asset Impairments, page 69 1.We note your discussion regarding the risk for asset impairments associated with owned facilities, including the carrying values of seven of your idled facilities as of December 31, 2022. Although you indicate your idled facilities are currently available and are being actively marketed to potential customers, considering five of the seven facilities listed with an aggregate carrying value of approximately $124 million have been idled since at least 2016, please further address in greater detail how you determined that each of the idled facilities have not been impaired during the fiscal years presented. In your response, tell us when you performed your impairment analysis and specifically address the assumptions as to the probability of obtaining future contracts to utilize such facilities in the future given the significant duration for which the facilities have been idle.
FirstName LastNameDavid M. Garfinkle Comapany NameCoreCivic, Inc. May 22, 2023 Page 2 FirstName LastName David M. Garfinkle CoreCivic, Inc. May 22, 2023 Page 2 In closing, 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 Mark Rakip, Staff Accountant at 202.551.3573 or Isaac Esquivel, Staff Accountant at 202.551.3395 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
May 22, 2023
David M. Garfinkle
Executive Vice President and Chief Financial Officer
CoreCivic, Inc.
5501 Virginia Way
Brentwood, TN 37027
Re:CoreCivic, Inc.
Form 10-K for fiscal year ended December 31, 2022
Filed February 21, 2023
File No. 001-16109
Dear David M. Garfinkle:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for fiscal year ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates
Asset Impairments, page 69
1.We note your discussion regarding the risk for asset impairments associated with owned
facilities, including the carrying values of seven of your idled facilities as of December
31, 2022. Although you indicate your idled facilities are currently available and are being
actively marketed to potential customers, considering five of the seven facilities listed
with an aggregate carrying value of approximately $124 million have been idled since at
least 2016, please further address in greater detail how you determined that each of the
idled facilities have not been impaired during the fiscal years presented. In your response,
tell us when you performed your impairment analysis and specifically address the
assumptions as to the probability of obtaining future contracts to utilize such facilities in
the future given the significant duration for which the facilities have been idle.
FirstName LastNameDavid M. Garfinkle
Comapany NameCoreCivic, Inc.
May 22, 2023 Page 2
FirstName LastName
David M. Garfinkle
CoreCivic, Inc.
May 22, 2023
Page 2
In closing, 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 Mark Rakip, Staff Accountant at 202.551.3573 or Isaac Esquivel, Staff
Accountant at 202.551.3395 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction