SEC Comment Letter for Travel & Leisure (TNL) — Mar 9, 2017
Travel & Leisure Co.
Date: March 9, 2017 · CIK: 0001361658 · Accession: 0000000000-17-007863
AI Filing Summary & Sentiment
File numbers found in text: 001-32876
Letter
Mail Stop 3233 March 9, 2017 Via E -mail Thomas G. Conforti Chief Financial Officer Wyndham Worldwide Corporation 22 Sylvan Way Parsippany, NJ 07054
Re: Wyndham Worldwide Corporation Form 10-K for the year ended December 31, 2016 Filed February 17, 2017 File No. 001-32876
Dear Mr. Conforti :
We have limited our review of your filing to the financial statements and related disclosures 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 will 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.
Item 7. Management’s discussion and Analysis of Financial C ondition and Results of Operations
Results of Operations, page 44
1. We note that your reconciliation of EBITDA starts with the non -GAAP measure and reconciles to the GAAP measure (net income). In future filings please revise your presentation to start wit h the GAAP measure so that the GAAP measure is presented with equal or greater prominence. This comment also applies to any non -GAAP measures presented in an earnings release. Refer to Question 102.10 of the Compliance and Disclosure Interpretations.
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.
Thomas G. Conforti Wyndham Worldwide Corporation March 9, 2017 Page 2
You may contact William Demarest, Accountant at 202 -551-3432 or me at 202 -551-3486 with any questions.
Sincerely,
/s/ Daniel L. Gordon
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Mail Stop 3233 March 9, 2017 Via E -mail Thomas G. Conforti Chief Financial Officer Wyndham Worldwide Corporation 22 Sylvan Way Parsippany, NJ 07054 Re: Wyndham Worldwide Corporation Form 10-K for the year ended December 31, 2016 Filed February 17, 2017 File No. 001-32876 Dear Mr. Conforti : We have limited our review of your filing to the financial statements and related disclosures 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 will 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. Item 7. Management’s discussion and Analysis of Financial C ondition and Results of Operations Results of Operations, page 44 1. We note that your reconciliation of EBITDA starts with the non -GAAP measure and reconciles to the GAAP measure (net income). In future filings please revise your presentation to start wit h the GAAP measure so that the GAAP measure is presented with equal or greater prominence. This comment also applies to any non -GAAP measures presented in an earnings release. Refer to Question 102.10 of the Compliance and Disclosure Interpretations. 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. Thomas G. Conforti Wyndham Worldwide Corporation March 9, 2017 Page 2 You may contact William Demarest, Accountant at 202 -551-3432 or me at 202 -551-3486 with any questions. Sincerely, /s/ Daniel L. Gordon Daniel L. Gordon Senior Assistant Chief Accountant Office of Real Estate & Commodities