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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

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
June 3, 2015
Author
/s/ Jennifer Monick
Form
UPLOAD
Company
Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640)

Letter

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

Show Raw Text
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