SEC Comment Letter for ALLIANCEBERNSTEIN L.P. (CIK 0001109448) — Mar 23, 2020
ALLIANCEBERNSTEIN L.P. (CIK 0001109448)
Date: March 23, 2020 · CIK: 0001109448 · Accession: 0000000000-20-002486
AI Filing Summary & Sentiment
File numbers found in text: 000-29961
Letter
March 19, 2020 John C. Weisenseel Chief Financial Officer AllianceBernstein L.P. 1345 Avenue of the Americas New York, NY 10105 Re:AllianceBernstein L.P. Form 10-K for the Fiscal Year Ended December, 31, 2019 Filed February 12, 2020 File No. 000-29961 Dear Mr. Weisenseel: We have limited our review of your filing to the financial statements and related disclosures 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 response. After reviewing your response to these comments, we may have additional comments. Form 10-K filed February 12, 2020 Management's Discussion and Analysis of Financial Condition and Results of Operations Management Operating Metrics, page 43 1.We note your disclosure on page 44 showing an adjustment for distribution-related payments to calculate Adjusted Net Revenues and Adjusted Operating Margin. In future filings, please revise to adjust by distribution revenues, rather than expenses, and provide supplemental information (e.g., footnote(s) to your reconciliation) to clearly explain each adjustment. To the extent that these distribution revenues are recognized in multiple revenue line items on the face of the income statement, disaggregate and distinguish the adjustment into those multiple components in the related non-GAAP reconciliation. In addition and if applicable, in periods when a material amount of fee waivers or other material non-standard items impact distribution revenues, provide disclosure quantifying the impact that it has or could have upon Adjusted Operating Margin, or any equivalent. In closing, we remind you that the company and its management are responsible for the
FirstName LastNameJohn C. Weisenseel Comapany NameAllianceBernstein L.P. March 19, 2020 Page 2 FirstName LastName John C. Weisenseel AllianceBernstein L.P. March 19, 2020 Page 2 accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Lory Empie, Staff Accountant at 202-551-3714 or Robert Klein, Staff Accountant at 202-551-3847 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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March 19, 2020
John C. Weisenseel
Chief Financial Officer
AllianceBernstein L.P.
1345 Avenue of the Americas
New York, NY 10105
Re:AllianceBernstein L.P.
Form 10-K for the Fiscal Year Ended December, 31, 2019
Filed February 12, 2020
File No. 000-29961
Dear Mr. Weisenseel:
We have limited our review of your filing to the financial statements and related
disclosures 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 response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K filed February 12, 2020
Management's Discussion and Analysis of Financial Condition and Results of Operations
Management Operating Metrics, page 43
1.We note your disclosure on page 44 showing an adjustment for distribution-related
payments to calculate Adjusted Net Revenues and Adjusted Operating Margin. In future
filings, please revise to adjust by distribution revenues, rather than expenses, and provide
supplemental information (e.g., footnote(s) to your reconciliation) to clearly explain each
adjustment. To the extent that these distribution revenues are recognized in multiple
revenue line items on the face of the income statement, disaggregate and distinguish the
adjustment into those multiple components in the related non-GAAP reconciliation. In
addition and if applicable, in periods when a material amount of fee waivers or other
material non-standard items impact distribution revenues, provide disclosure quantifying
the impact that it has or could have upon Adjusted Operating Margin, or any equivalent.
In closing, we remind you that the company and its management are responsible for the
FirstName LastNameJohn C. Weisenseel
Comapany NameAllianceBernstein L.P.
March 19, 2020 Page 2
FirstName LastName
John C. Weisenseel
AllianceBernstein L.P.
March 19, 2020
Page 2
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Lory Empie, Staff Accountant at 202-551-3714 or Robert Klein, Staff
Accountant at 202-551-3847 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance