SEC Company Response from Teekay LNG Partners L.P. (SEAL-PA, SEAL-PB) (CIK 0001308106) (SEAL-PA) — Nov 25, 2020
Teekay LNG Partners L.P. (SEAL-PA, SEAL-PB) (CIK 0001308106)
Date: Nov. 25, 2020 · CIK: 0001308106 · Accession: 0001193125-20-303575
AI Filing Summary & Sentiment
File numbers found in text: 001-32479
Letter
United States Securities and Exchange Commission Division of Corporate Finance Form 20-F for Fiscal Year Ended December 31, 2019 Filed April 9, 2020 Form 6-K Filed August 13, 2020 File No. 001-32479
Re:
Dear Mr. Rodriguez:
We have reviewed your letter to us of November 13, 2020 setting forth staff comments on Teekay LNG Partners L.P.’s (“Teekay LNG” or the “Partnership”) Form 6-K filed August 13, 2020. This letter responds to the comment made by the staff in your letter. For your convenience, the response has been keyed to the comment.
Form 6-K Filed August 13, 2020
Definitions and Non-GAAP Financial Measures, page 6
SEC Comment
1. We have reviewed your response to comment 1. Your presentation of the non-GAAP measure Adjusted Revenues includes revenues based on your proportionate economic ownership of each vessel owned by your equity-accounted joint ventures. Presentation of revenue based on proportionate consolidation is appropriate only in limited circumstances, none of which appear to apply to you. As a result, your use of proportionate consolidation appears to represent the use of a tailored accounting principle. Revise your presentation to remove revenue recognized based on the use of proportionate consolidation. See FASB ASC paragraphs 323-10-45-1 and 810-10-45-14 and C&DI Question 100.04.
Response to SEC Comment 1:
In future filings, the Partnership will revise its presentation to remove revenue recognized based on the use of proportionate consolidation.
* * * * *
We appreciate the opportunity to respond to the comment provided.
Sincerely,
/s/ Scott Gayton
Show Raw Text
CORRESP 1 filename1.htm CORRESP November 25, 2020 Gus Rodriguez, Accounting Branch Chief United States Securities and Exchange Commission Division of Corporate Finance 100 F Street N.E. Washington, DC 20549 Re: Teekay LNG Partners L.P. Form 20-F for Fiscal Year Ended December 31, 2019 Filed April 9, 2020 Form 6-K Filed August 13, 2020 File No. 001-32479 Dear Mr. Rodriguez: We have reviewed your letter to us of November 13, 2020 setting forth staff comments on Teekay LNG Partners L.P.’s (“Teekay LNG” or the “Partnership”) Form 6-K filed August 13, 2020. This letter responds to the comment made by the staff in your letter. For your convenience, the response has been keyed to the comment. Form 6-K Filed August 13, 2020 Definitions and Non-GAAP Financial Measures, page 6 SEC Comment 1. We have reviewed your response to comment 1. Your presentation of the non-GAAP measure Adjusted Revenues includes revenues based on your proportionate economic ownership of each vessel owned by your equity-accounted joint ventures. Presentation of revenue based on proportionate consolidation is appropriate only in limited circumstances, none of which appear to apply to you. As a result, your use of proportionate consolidation appears to represent the use of a tailored accounting principle. Revise your presentation to remove revenue recognized based on the use of proportionate consolidation. See FASB ASC paragraphs 323-10-45-1 and 810-10-45-14 and C&DI Question 100.04. Response to SEC Comment 1: In future filings, the Partnership will revise its presentation to remove revenue recognized based on the use of proportionate consolidation. * * * * * We appreciate the opportunity to respond to the comment provided. Sincerely, /s/ Scott Gayton Scott Gayton Chief Financial Officer, Teekay Gas Group Ltd. (Principal Financial and Accounting Officer) cc: Alan Semple (Audit Committee Chair) David Matheson (Perkins Coie LLP) Philippa Wilshaw (KPMG LLP)