SEC Comment Letter for Clear Channel Outdoor Holdings, Inc. (CCO) (CIK 0001334978) (CCO) — Aug 2, 2017
Clear Channel Outdoor Holdings, Inc. (CCO) (CIK 0001334978)
Date: Aug. 2, 2017 · CIK: 0001334978 · Accession: 0000000000-17-027253
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3720 August 2, 2017 Richard J. Bressler Chief Financial Officer Clear Channel Outdoor Holdings, Inc. 200 East Basse Road, Suite 100 San Antonio, Texas 78209
Re: Clear Channel Outdoor Holdings, Inc. Form 10 -K for Fiscal Year Ended December 31, 2016 Filed February 23, 2017 File No. 1 -32663
Dear Mr. Bressler :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment . Please co mply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. 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 business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and cir cumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Notes to Consolidated Financial Statements
Note 11 – Segment Data, page 83
We note in your discussion of operating resu lts that you refer to specific countries and discuss their impact on operations. For example, in the discussion of your International Outdoor R esults of Operations, on page 35 , you note that lower rent expense and revenues due to the non -renewal of a bus shelter contract in the United Kingdom was a driver for the decrease in direct operating expenses. Please tell us how you considered the guidance in ASC 280 -10-50-41(a) in determining whether to present geographic information by country in your segment di sclosures.
Richard J. Bressler Clear Channel Outdoor Holdings , Inc. August 2, 2017 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Charles Eastman, Senior Staff Accountant at (202) 551 -3794 or Terry French, Accounting Branch Chief, at (202) 551 -3828 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Terry French for
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Mail Stop 3720 August 2, 2017 Richard J. Bressler Chief Financial Officer Clear Channel Outdoor Holdings, Inc. 200 East Basse Road, Suite 100 San Antonio, Texas 78209 Re: Clear Channel Outdoor Holdings, Inc. Form 10 -K for Fiscal Year Ended December 31, 2016 Filed February 23, 2017 File No. 1 -32663 Dear Mr. Bressler : We have limited our review of your filing to the financial statements and related disclosures and have the following comment . Please co mply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. 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 business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and cir cumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Notes to Consolidated Financial Statements Note 11 – Segment Data, page 83 We note in your discussion of operating resu lts that you refer to specific countries and discuss their impact on operations. For example, in the discussion of your International Outdoor R esults of Operations, on page 35 , you note that lower rent expense and revenues due to the non -renewal of a bus shelter contract in the United Kingdom was a driver for the decrease in direct operating expenses. Please tell us how you considered the guidance in ASC 280 -10-50-41(a) in determining whether to present geographic information by country in your segment di sclosures. Richard J. Bressler Clear Channel Outdoor Holdings , Inc. August 2, 2017 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Charles Eastman, Senior Staff Accountant at (202) 551 -3794 or Terry French, Accounting Branch Chief, at (202) 551 -3828 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Terry French for Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications