SEC Comment Letter for ASHFORD HOSPITALITY TRUST INC (AHT, AHT-PD, AHT-PF, AHT-PG, AHT-PH, AHT-PI) (CIK 0001232582) (AHT) — Dec 2, 2015
ASHFORD HOSPITALITY TRUST INC (AHT, AHT-PD, AHT-PF, AHT-PG, AHT-PH, AHT-PI) (CIK 0001232582)
Date: Dec. 2, 2015 · CIK: 0001232582 · Accession: 0000000000-15-056182
AI Filing Summary & Sentiment
Referenced dates: September 29, 2015
Letter
Mail Stop 3233 December 2, 2015 Via E -mail Mr. Deric S. Eubanks Chief Financial Officer Ashford Hospitality Trust, Inc. 14185 Dallas Parkway, Suite 1100 Dallas, TX 75254
Re: Ashford Hospitality Trust, Inc. Form 10-K for the fiscal year ended December 31, 2014 Response Dated November 12 , 2015 File No. 1 -31775
Dear Mr. Eubanks :
We have reviewed your November 12, 2015 response to our comment letter 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 busine ss days by providing the requested information or advis e us as soon as possible when you wi ll 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. Unless we note otherwise, our references to prior comments are to comments in our October 29, 2015 letter .
Form 8 -K filed August 6, 2015
Exhibit 99.1
1. We note your response to our prior comment one and your proposed disclosure. To the extent you disclose an implied share price in future press releases, please also quantitatively disclose the key assumptions used in determining the implied share price. For example, please consider disclosing the second table you provided in response to comment six from our letter dated September 29, 2015. Fur ther, please reconcile TTM Hotel NOI to the most directly comparable GAAP measure .
Mr. Deric S. Eubanks Ashford Hospitality Trust, Inc. December 2 , 2015 Page 2
You may contact Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or me at (202) 551 - 3295 if you have questions regarding comments on the financial statements and re lated matters. Please contact Jerard Gibson, Staff Attorney, at (202) 551 -3473 or Sonia Barros, Assistant Director, at (202) 551 -3655 with any other questions.
Sincerely,
/s/ Jennifer Monick
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Mail Stop 3233 December 2, 2015 Via E -mail Mr. Deric S. Eubanks Chief Financial Officer Ashford Hospitality Trust, Inc. 14185 Dallas Parkway, Suite 1100 Dallas, TX 75254 Re: Ashford Hospitality Trust, Inc. Form 10-K for the fiscal year ended December 31, 2014 Response Dated November 12 , 2015 File No. 1 -31775 Dear Mr. Eubanks : We have reviewed your November 12, 2015 response to our comment letter 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 busine ss days by providing the requested information or advis e us as soon as possible when you wi ll 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. Unless we note otherwise, our references to prior comments are to comments in our October 29, 2015 letter . Form 8 -K filed August 6, 2015 Exhibit 99.1 1. We note your response to our prior comment one and your proposed disclosure. To the extent you disclose an implied share price in future press releases, please also quantitatively disclose the key assumptions used in determining the implied share price. For example, please consider disclosing the second table you provided in response to comment six from our letter dated September 29, 2015. Fur ther, please reconcile TTM Hotel NOI to the most directly comparable GAAP measure . Mr. Deric S. Eubanks Ashford Hospitality Trust, Inc. December 2 , 2015 Page 2 You may contact Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or me at (202) 551 - 3295 if you have questions regarding comments on the financial statements and re lated matters. Please contact Jerard Gibson, Staff Attorney, at (202) 551 -3473 or Sonia Barros, Assistant Director, at (202) 551 -3655 with any other questions. Sincerely, /s/ Jennifer Monick Jennifer Monick Assistant Chief Accountant Office of Real Estate and Commodities