SEC Comment Letter for Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640) (MLCO) — Jun 3, 2015
Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640)
Date: June 3, 2015 · CIK: 0001381640 · Accession: 0000000000-15-029515
AI Filing Summary & Sentiment
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June 3, 2015
Via E -Mail
Geoffrey Davis
Chief Financial Officer
Melco Crown Entertainment Limited
36th Floor, The Centrium
60 Wyndham Street
Central, Hong Kong
Re: Melco Crown Entertainment Limited
Form 20-F for the Fiscal Ye ar Ended December 31, 20 14
Filed April 15, 201 5
File No. 001 -33178
Dear Mr. Davis :
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we 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 appl ies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment, we may have additional
comments.
Notes to Consolidated Financial Statements
23. Commitments and Contingencies
(e) Litigation, page F -69
1. Please clarify for us and in future period filings if you expect the indictment from the
Taipei District Prosecutors Office to have a material impact on your financial
statements as a whole, as opposed to just your business operations or financial
position . Additionally, in your revised disclosure, please either (1) do not qualify
your disclosure with the phrase “immediate” or (2) expand your disclosure to discuss
the expected impact beyond the “immediate.” Within your response, please provide
an example o f your proposed disclosure.
Geoffrey Davis
Melco Crown Entertainment Limited
June 3, 2015
Page 2
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 the information the Securities
Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company
and its management are in possession of all facts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our commen t, please provide a written statement from the
company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose th e Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.
If you have any questions, you may contact Jorge L. Bonilla at (202) 551 -3414 or
me at (202) 551 -3295.
Sincerely,
/s/ Jennifer Monick
Jennifer Monick
Senior Staff Accountant