SEC Comment Letter for AlerisLife Inc. (CIK 0001159281) — Oct 11, 2005
AlerisLife Inc. (CIK 0001159281)
Date: Oct. 11, 2005 · CIK: 0001159281 · Accession: 0000000000-05-052064
AI Filing Summary & Sentiment
Referenced dates: June 17, 2005, June 3, 2005
Letter
September 23, 2005 Via U.S. Mail and Fax Mr. Bruce J. Mackey Jr. Treasurer and Chief Financial Officer Five Star Quality Care, Inc. 400 Centre Street Newton, MA 02458
RE: Five Star Quality Care, Inc. Form 10-K for the fiscal year ended December 31, 2004 Filed March 29, 2005 Form 10-Q for Fiscal Quarters Ended March 31, 2005 and June 30, 2005 File No. 1-16817
Dear Mr. Mackey:
We have reviewed your supplemental response letter dated June 17, 2005 and have the following comment. As noted in our comment letter dated June 3, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
Form 10-K for the fiscal year ending December 31, 2004 Continuing care contracts and Revenue Recognition, page F-8
You indicate in your response to comment 2 that a portion of the advance payments for continuing care contracts are refundable and considered due on demand. We believe you should apply the guidance in SFAS 78 in evaluating the appropriate classification of refundable advance payments. For any entrance fee refund obligations that by their terms may be voluntarily terminated by the resident, resulting in the obligation to pay a refund to the resident within twelve months of termination, the guidance contained in SFAS 78 requires classification of the refund obligation as a current liability. Additionally, in determining the portion of the entrance fee related liabilities that should be classified as current liabilities, you should include the entire amount of potential refund as of the balance sheet date presented regardless of the likelihood or probability that it will be called.
In your next filing on Form 10-Q, please reassess your accounting using the guidance of SFAS 78.
Please respond to this comment within 10 business days or tell us when you will provide us with a response. You may contact Nasreen Mohammed, Staff Accountant, at (202) 551-3773 or Terry French, Accountant Branch Chief, at (202) 551-3828 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 with any other questions.
Sincerely,
/s/ Terry French
for Larry Spirgel
Assistant Director
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<TEXT>
September 23, 2005
Via U.S. Mail and Fax
Mr. Bruce J. Mackey Jr.
Treasurer and Chief Financial Officer
Five Star Quality Care, Inc.
400 Centre Street
Newton, MA 02458
RE: Five Star Quality Care, Inc.
Form 10-K for the fiscal year ended December 31, 2004
Filed March 29, 2005
Form 10-Q for Fiscal Quarters Ended March 31, 2005 and
June
30, 2005
File No. 1-16817
Dear Mr. Mackey:
We have reviewed your supplemental response letter dated
June
17, 2005 and have the following comment. As noted in our comment
letter dated June 3, 2005, we have limited our review to your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.
Form 10-K for the fiscal year ending December 31, 2004
Continuing care contracts and Revenue Recognition, page F-8
You indicate in your response to comment 2 that a portion of the
advance payments for continuing care contracts are refundable and
considered due on demand. We believe you should apply the
guidance
in SFAS 78 in evaluating the appropriate classification of
refundable
advance payments. For any entrance fee refund obligations that by
their terms may be voluntarily terminated by the resident,
resulting
in the obligation to pay a refund to the resident within twelve
months of termination, the guidance contained in SFAS 78 requires
classification of the refund obligation as a current liability.
Additionally, in determining the portion of the entrance fee
related
liabilities that should be classified as current liabilities, you
should include the entire amount of potential refund as of the
balance sheet date presented regardless of the likelihood or
probability that it will be called.
In your next filing on Form 10-Q, please reassess your accounting
using the guidance of SFAS 78.
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. You may contact
Nasreen
Mohammed, Staff Accountant, at (202) 551-3773 or Terry French,
Accountant Branch Chief, at (202) 551-3828 if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3810 with any other questions.
Sincerely,
/s/ Terry French
for Larry Spirgel
Assistant Director
??
??
??
??
Mr. Bruce Mackey
Five Star Quality Care, Inc.
September 23, 2005
Page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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