SEC Comment Letter for Ares Management (ARES) — Jan 7, 2014
Ares Management Corp
Date: Jan. 7, 2014 · CIK: 0001176948 · Accession: 0000000000-14-000731
AI Filing Summary & Sentiment
Letter
January 7, 2013 Michael D. Weiner Executive Vice President and Chief Legal Officer Ares Management, L.P. 2000 Avenue of the Stars 12th Floor Los Angeles, CA 90067
Re: Ares Management, L.P. Draft Registration Statement on Form S-1 Submitted December 24, 2013 CIK 000176948
Dear Mr. Weiner
Our preliminary review of your registration statement indicates that it is materially incomplete as it does not include any pro forma information about the reorganization and offering adjustments . Therefore, it does not comply with the requirements of the Securities Act of 1933, the rules and regulations under that Act, and the requirements of the form. We will not perform a detailed examination of the registration statement and we will not issue comments because to do so would delay th e review of other disclosure documents that do not appear to contain comparable deficiencies.
If you were to request acceleration of the effective date of the registration statement in its present form, we would likely recommend that the Commission deny y our request. We suggest that you consider filing a substantive amendment to correct the deficiencies.
Sincerely,
/s/ Suzanne H ayes
Assistant Director
Suzanne Hayes
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January 7, 2013 Michael D. Weiner Executive Vice President and Chief Legal Officer Ares Management, L.P. 2000 Avenue of the Stars 12th Floor Los Angeles, CA 90067 Re: Ares Management, L.P. Draft Registration Statement on Form S-1 Submitted December 24, 2013 CIK 000176948 Dear Mr. Weiner Our preliminary review of your registration statement indicates that it is materially incomplete as it does not include any pro forma information about the reorganization and offering adjustments . Therefore, it does not comply with the requirements of the Securities Act of 1933, the rules and regulations under that Act, and the requirements of the form. We will not perform a detailed examination of the registration statement and we will not issue comments because to do so would delay th e review of other disclosure documents that do not appear to contain comparable deficiencies. If you were to request acceleration of the effective date of the registration statement in its present form, we would likely recommend that the Commission deny y our request. We suggest that you consider filing a substantive amendment to correct the deficiencies. Sincerely, /s/ Suzanne H ayes Assistant Director Suzanne Hayes