SEC Comment Letter for Sunstone Hotel Investors, Inc. (SHO, SHO-PH, SHO-PI) (CIK 0001295810) (SHO) — Oct 24, 2006
Sunstone Hotel Investors, Inc. (SHO, SHO-PH, SHO-PI) (CIK 0001295810)
Date: Oct. 24, 2006 · CIK: 0001295810 · Accession: 0000000000-06-051760
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-32319
Referenced dates: October 10, 2006
Letter
Mail Stop 4561 October 24, 2006 Jon D. Kline 903 Calle Amanecer, Suite 100 San Clemente, CA 92673
Re: Sunstone Hotel Investors, Inc. Form 10-K for Fiscal Ye ar Ended December 31, 2005 Forms 10-Q for Fiscal Quarters E nded March 31, 200 6 and June 30, File No. 001-32319
Dear Mr. Kline:
We have reviewed your response letter dated October 10, 2006, and have the following additional comments.
Form 10-K
Note 12 - Shareholders’ Equity, page F-25
Common Stock, page F-26 1. We have read and considered your respons e to comment two. Since the registrant elected to recognize the rela ted compensation cost on a st raight-line basis over the requisite period for the entire award, it st ill remains unclear how the vesting is being accounted for in the company’s financial statements. Please clarify to us the amount of compensation expense that was recognized and the amount of shares that were issued, if any, as of December 31, 2005 and how they were recognized in the financial statements.
Form 10-Q for the Quarter Period June 30, 2006
Note 13 – Subsequent Events, page 12 2. We note that you entered into a forwar d sale agreement on July 18, 2006 relating to 4,000,000 shares of common stock. We note that the initial forward price is reduced by certain specified amounts on the 15th day of January, April, July and October for expected quarterly dividends. Please tell us how you plan to account
Jon D. Kline Sunstone Hotel Investors, Inc. October 24, 2006 Page 2 for the earnings per share impact of this forward sale agreem ent, specifically addressing the guidance in paragraph 11 of EITF 03-6.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Detailed cover letters gr eatly facilitate our review. Please file your cover letter on E DGAR. Please understa nd that we may have additional comments after reviewin g your responses to our comments.
You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3498 if you have questions.
Sincerely,
Linda VanDoorn
Senior Assistant Chief Accountant
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Mail Stop 4561 October 24, 2006 Jon D. Kline 903 Calle Amanecer, Suite 100 San Clemente, CA 92673 Re: Sunstone Hotel Investors, Inc. Form 10-K for Fiscal Ye ar Ended December 31, 2005 Forms 10-Q for Fiscal Quarters E nded March 31, 200 6 and June 30, 2006 File No. 001-32319 Dear Mr. Kline: We have reviewed your response letter dated October 10, 2006, and have the following additional comments. Form 10-K Note 12 - Shareholders’ Equity, page F-25 Common Stock, page F-26 1. We have read and considered your respons e to comment two. Since the registrant elected to recognize the rela ted compensation cost on a st raight-line basis over the requisite period for the entire award, it st ill remains unclear how the vesting is being accounted for in the company’s financial statements. Please clarify to us the amount of compensation expense that was recognized and the amount of shares that were issued, if any, as of December 31, 2005 and how they were recognized in the financial statements. Form 10-Q for the Quarter Period June 30, 2006 Note 13 – Subsequent Events, page 12 2. We note that you entered into a forwar d sale agreement on July 18, 2006 relating to 4,000,000 shares of common stock. We note that the initial forward price is reduced by certain specified amounts on the 15th day of January, April, July and October for expected quarterly dividends. Please tell us how you plan to account Jon D. Kline Sunstone Hotel Investors, Inc. October 24, 2006 Page 2 for the earnings per share impact of this forward sale agreem ent, specifically addressing the guidance in paragraph 11 of EITF 03-6. * * * * As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Detailed cover letters gr eatly facilitate our review. Please file your cover letter on E DGAR. Please understa nd that we may have additional comments after reviewin g your responses to our comments. You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3498 if you have questions. Sincerely, Linda VanDoorn Senior Assistant Chief Accountant