SEC Comment Letter for Travel & Leisure (TNL) — Sep 5, 2008
Travel & Leisure Co.
Date: Sept. 5, 2008 · CIK: 0001361658 · Accession: 0000000000-08-044631
AI Filing Summary & Sentiment
File numbers found in text: 001-32876
Referenced dates: August 19, 2008
Letter
Re: Wyndham Worldwide Corporation Form 10-K for the year ended December 31, 2007 Filed 02/29/08 File No. 001-32876 Dear Mr. Holmes: We have reviewed your response letter dated August 19, 2008 and have the following additional comment. Where indi cated, we think you should revise your documents in response to this comment in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. After reviewing this information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the year ended December 31, 2007
Mail Stop 4561 September 4, 2008 Mr. Stephen P. Holmes Chief Executive Officer Wyndham Worldwide Corporation Seven Sylvan Way Parsippany, NJ 07054
Consolidated and Combined Statements of Cash Flows, page F-5
1. We note your response to comment 3; however, we continue to believe that your cash flows should be classified according to the nature of the activities that are likely to be the predominate sources of the cash flows in accordance with paragraph 87 of SFAS 95. In future filings, please revise accordingly.
Mr. Stephen P. Holmes Wyndham Worldwide Corporation September 4, 2008 Page 2 ******
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please understa nd that we may have additional comments after reviewing your response to our comment.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filings or in response to our comments on your filing. You may contact Jessica Ba rberich at (202) 551-3782 or me at (202) 551-3486 if you have questions regarding comments on the financial statements and related matters.
S i n c e r e l y , Daniel Gordon Branch Chief
Show Raw Text
Mail Stop 4561
September 4, 2008
Mr. Stephen P. Holmes Chief Executive Officer Wyndham Worldwide Corporation Seven Sylvan Way Parsippany, NJ 07054
Re: Wyndham Worldwide Corporation
Form 10-K for the year ended December 31, 2007
Filed 02/29/08
File No. 001-32876
Dear Mr. Holmes:
We have reviewed your response letter dated August 19, 2008 and have the
following additional comment. Where indi cated, we think you should revise your
documents in response to this comment in future filings. If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. After reviewing this
information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the year ended December 31, 2007
Consolidated and Combined Statements of Cash Flows, page F-5
1. We note your response to comment 3; however, we continue to believe that your
cash flows should be classified according to the nature of the activities that are
likely to be the predominate sources of the cash flows in accordance with
paragraph 87 of SFAS 95. In future filings, please revise accordingly.
Mr. Stephen P. Holmes
Wyndham Worldwide Corporation September 4, 2008 Page 2
******
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please understa nd that we may have additional comments
after reviewing your response to our comment.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filing.
You may contact Jessica Ba rberich at (202) 551-3782 or me at (202) 551-3486 if
you have questions regarding comments on the financial statements and related matters.
S i n c e r e l y ,
Daniel Gordon Branch Chief