SEC Comment Letter for ASHFORD HOSPITALITY TRUST INC (AHT, AHT-PD, AHT-PF, AHT-PG, AHT-PH, AHT-PI) (CIK 0001232582) (AHT) — Dec 7, 2009
ASHFORD HOSPITALITY TRUST INC (AHT, AHT-PD, AHT-PF, AHT-PG, AHT-PH, AHT-PI) (CIK 0001232582)
Date: Dec. 7, 2009 · CIK: 0001232582 · Accession: 0000000000-09-068939
AI Filing Summary & Sentiment
File numbers found in text: 001-31775
Referenced dates: September 29, 2009
Letter
Mail Stop 3010 December 7, 2009 VIA FAX (972) 490- 9605 AND USMAIL Mr. David J. Kimichik Chief Financial Officer Ashford Hospitality Trust 14185 Dallas Parkway, Suite 1100 Dallas, Texas 75254
Re: Ashford Hospitality Trust Form 10-K for the year ended December 31, 2008 filed February 27, 2009 Form 10-K/A for the year ended December 31, 2008 filed May 5, 2009 Form 10-Q for the three months ended March 31, 2009 Form 10-Q for the three and six months ended June 30, 2009 Form 10-Q for the three and nine months ended September 30, 2009 Definitive Proxy Statement filed April 17, 2009 File No. 001-31775
Dear Mr. David J. Kimichik:
We have reviewed your response lette r dated October 14, 2009 and have the following additional comments. Where i ndicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Provide to us the information requested if indi cated and please be as detailed as necessary in your explanation. U
DEFINITIVE PROXY STATME NENT FILED APRIL 17, 2009 1. We note your response to comment 7 of our letter dated September 29, 2009. In response to our comment, you state that total compensation for all executive officers fell below the targeted level. In future filings, please disclose, for each executive officer, whether their respectiv e total compensation falls within the targeted parameters, and to the extent an officer receives compensation above or below the targeted parameter, please incl ude an explanation of the reasons for this.
David J. Kimichik Ashford Hospitality Trust December 7, 2009 Page 2 FORM 10-Q FOR THE NINE MONTHS ENDED SEPTEMBER 30, 2009
Financial Statements and Notes
Notes Receivable, page 23
2. In your response to comments 4 and 13, you state that your loans have unique characteristics and therefore there is no r easonable basis to evaluate the loans as a group. While we understand these loan ch aracteristics may be a factor in assessing a loss based on the accounti ng literature covering losses from uncollectible receivables, we are unclear how you have addressed whether there is a loss in value in light of the current economic environment. Reference is made to FASB ASC 310-10-35-9 through 310-10-35-11.
*** As appropriate, please respond to these comm ents within 10 business days or tell us when you will provide us with a respons e. Please understand that we may have additional comments after reviewin g your responses to our comments.
You may contact Jaime John at (202) 551-3446 or me at (202) 551-3413 if you have questions regarding comments on the fi nancial statements and related matters. Please contact Stacy Gorman at ( 202) 551-3585 with any other questions.
S i n c e r e l y , Cicely LaMothe Accounting Branch Chief
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Mail Stop 3010 December 7, 2009 VIA FAX (972) 490- 9605 AND USMAIL
Mr. David J. Kimichik Chief Financial Officer Ashford Hospitality Trust 14185 Dallas Parkway, Suite 1100 Dallas, Texas 75254
Re: Ashford Hospitality Trust
Form 10-K for the year ended December 31, 2008 filed February 27, 2009 Form 10-K/A for the year ended December 31, 2008 filed May 5, 2009 Form 10-Q for the three months ended March 31, 2009 Form 10-Q for the three and six months ended June 30, 2009 Form 10-Q for the three and nine months ended September 30, 2009
Definitive Proxy Statement filed April 17, 2009 File No. 001-31775
Dear Mr. David J. Kimichik:
We have reviewed your response lette r dated October 14, 2009 and have the
following additional comments. Where i ndicated, we think you should revise your
documents in response to these comments. If you disagree, we will consider your
explanation as to why our comments are inapplicable or a revision is unnecessary. Provide to us the information requested if indi cated and please be as detailed as necessary
in your explanation.
U
DEFINITIVE PROXY STATME NENT FILED APRIL 17, 2009
1. We note your response to comment 7 of our letter dated September 29, 2009. In
response to our comment, you state that total compensation for all executive
officers fell below the targeted level. In future filings, please disclose, for each
executive officer, whether their respectiv e total compensation falls within the
targeted parameters, and to the extent an officer receives compensation above or below the targeted parameter, please incl ude an explanation of the reasons for
this.
David J. Kimichik
Ashford Hospitality Trust December 7, 2009 Page 2 FORM 10-Q FOR THE NINE MONTHS ENDED SEPTEMBER 30, 2009
Financial Statements and Notes
Notes Receivable, page 23
2. In your response to comments 4 and 13, you state that your loans have unique
characteristics and therefore there is no r easonable basis to evaluate the loans as a
group. While we understand these loan ch aracteristics may be a factor in
assessing a loss based on the accounti ng literature covering losses from
uncollectible receivables, we are unclear how you have addressed whether there is
a loss in value in light of the current economic environment. Reference is made to FASB ASC 310-10-35-9 through 310-10-35-11.
***
As appropriate, please respond to these comm ents within 10 business days or tell
us when you will provide us with a respons e. Please understand that we may have
additional comments after reviewin g your responses to our comments.
You may contact Jaime John at (202) 551-3446 or me at (202) 551-3413 if you
have questions regarding comments on the fi nancial statements and related matters.
Please contact Stacy Gorman at ( 202) 551-3585 with any other questions.
S i n c e r e l y ,
Cicely LaMothe
Accounting Branch Chief