SEC Comment Letter for National CineMedia, Inc. (NCMI) (CIK 0001377630) (NCMI) — Jul 10, 2018
National CineMedia, Inc. (NCMI) (CIK 0001377630)
Date: July 10, 2018 · CIK: 0001377630 · Accession: 0000000000-18-021111
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33296
Letter
July 10, 2018 Katherine L. Scherping Chief Financial Officer National CineMedia, Inc. 9110 East Nichols Ave. Suite 200 Centennial, CO 80112 Re:National CineMedia, Inc. Form 10-K for Fiscal Year Ended December 28, 2017 Filed March 19, 2018 Form 10-Q for Fiscal Quarter Ended March 29, 2018 Filed May 8, 2018 File No. 001-33296 Dear Ms. Scherping: We have limited our review of your filings to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended December 28, 2017 Note 18. Correction of an Error, page F-37 1.Please clearly explain to us, in detail, the nature of the errors in your previously issued financial statements including a reference to the specific accounting literature that was misapplied. Provide us an explanation of you prior accounting and how you corrected it including how you determined the correction amounts. Also tell us why it was necessary to adjust each of the balance sheet line-items in the table on page F-38. 2.Please provide us with your assessment of the materiality of the errors identified in your
FirstName LastNameKatherine L. Scherping Comapany NameNational CineMedia, Inc. July 10, 2018 Page 2 FirstName LastName Katherine L. Scherping National CineMedia, Inc. July 10, 2018 Page 2 historical financial statements. We refer you to the guidance in SAB Topics 1:M and 1:N. Form 10-Q for Fiscal Quarter Ended March 29, 2018 Change in Accounting Principle and Correction of an Error, page 9 3.Please explain to us the facts and circumstances concerning the change in accounting principle, including an explanation of previous generally accepted accounting principle and the newly adopted generally accepted accounting principle. Provide us specific references in the accounting literature as support for both the newly adopted and previous accounting policies. In closing, 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 Joseph Cascarano, Staff Accountant, at 202-551-3376 or Robert S. Littlepage, Accountant Branch Chief, at 202-551-3376 with any questions. Division of Corporation Finance Office of Telecommunications
Show Raw Text
July 10, 2018
Katherine L. Scherping
Chief Financial Officer
National CineMedia, Inc.
9110 East Nichols Ave.
Suite 200
Centennial, CO 80112
Re:National CineMedia, Inc.
Form 10-K for Fiscal Year Ended December 28, 2017
Filed March 19, 2018
Form 10-Q for Fiscal Quarter Ended March 29, 2018
Filed May 8, 2018
File No. 001-33296
Dear Ms. Scherping:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 28, 2017
Note 18. Correction of an Error, page F-37
1.Please clearly explain to us, in detail, the nature of the errors in your previously issued
financial statements including a reference to the specific accounting literature that was
misapplied. Provide us an explanation of you prior accounting and how you corrected it
including how you determined the correction amounts. Also tell us why it was necessary
to adjust each of the balance sheet line-items in the table on page F-38.
2.Please provide us with your assessment of the materiality of the errors identified in your
FirstName LastNameKatherine L. Scherping
Comapany NameNational CineMedia, Inc.
July 10, 2018 Page 2
FirstName LastName
Katherine L. Scherping
National CineMedia, Inc.
July 10, 2018
Page 2
historical financial statements. We refer you to the guidance in SAB Topics 1:M and 1:N.
Form 10-Q for Fiscal Quarter Ended March 29, 2018
Change in Accounting Principle and Correction of an Error, page 9
3.Please explain to us the facts and circumstances concerning the change in accounting
principle, including an explanation of previous generally accepted accounting principle
and the newly adopted generally accepted accounting principle. Provide us specific
references in the accounting literature as support for both the newly adopted and previous
accounting policies.
In closing, 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 Joseph Cascarano, Staff Accountant, at 202-551-3376 or Robert S.
Littlepage, Accountant Branch Chief, at 202-551-3376 with any questions.
Division of Corporation Finance
Office of Telecommunications