SEC Comment Letter for Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640) (MLCO) — Jul 18, 2016
Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640)
Date: July 18, 2016 · CIK: 0001381640 · Accession: 0000000000-16-084617
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3233 July 15, 2016 Via E -Mail Geoffrey Stuart 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 year ended December 31, 2015 Filed April 12, 2016 File No. 1 -33178
Dear Mr. Davis:
We have reviewed your July 6, 2016 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our June 7, 2016 letter .
Item 18. Financial Statements
Note 2. Summary of Significant Accounting Policies
(n) Land Use Rights, Net, page F -17 1. We note your response to prior comments 1 and 2. Please further elaborate on how you assumed that your land concession contracts in Macau were reasonably expected to be renewed by addressing the following: a. You indicate that all remaining construction requirements and administrative registration procedures should be within your control. Tell u s what, if any,
Geoffrey Stuart Davis Melco Crown Entertainment Limited July 15, 2016 Page 2
remaining requirements and procedures are outside of your control, including any applicable legislation in Macau. b. You disclose there is no guarantee you will complete the development of the fifth hotel tower at City of Dreams or the remaini ng undeveloped land at Studio City by the required deadline s. Provide to us internal assessments supporting your conclusion that the material terms of the land concession contracts will be met by the required 2018 deadlines and are therefore reasonably expected to be renewed. c. It appears that you do not have any remaining developm ent projects related to your Altira Macau property; please advise. Additionally, tell us what consideration you gave to reassessing the land concession contracts related to your Altira Macau property in December 2013 given the land grant for such property was amended at that time. Further, detail the specific factors that changed on October 1 , 2015 for you to conclude that the amortization period for land use rights related to Altira Macau were extended to 40 years on that date, but not in December 2013. You may contact Mark Rakip, Staff Accountant at 202.551.3573 or me at 202.551.3429 if you have questions regarding comments on the financial s tatements and related matters.
Sincerely,
/s/ Kristi Marrone
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Mailstop 3233 July 15, 2016 Via E -Mail Geoffrey Stuart 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 year ended December 31, 2015 Filed April 12, 2016 File No. 1 -33178 Dear Mr. Davis: We have reviewed your July 6, 2016 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our June 7, 2016 letter . Item 18. Financial Statements Note 2. Summary of Significant Accounting Policies (n) Land Use Rights, Net, page F -17 1. We note your response to prior comments 1 and 2. Please further elaborate on how you assumed that your land concession contracts in Macau were reasonably expected to be renewed by addressing the following: a. You indicate that all remaining construction requirements and administrative registration procedures should be within your control. Tell u s what, if any, Geoffrey Stuart Davis Melco Crown Entertainment Limited July 15, 2016 Page 2 remaining requirements and procedures are outside of your control, including any applicable legislation in Macau. b. You disclose there is no guarantee you will complete the development of the fifth hotel tower at City of Dreams or the remaini ng undeveloped land at Studio City by the required deadline s. Provide to us internal assessments supporting your conclusion that the material terms of the land concession contracts will be met by the required 2018 deadlines and are therefore reasonably expected to be renewed. c. It appears that you do not have any remaining developm ent projects related to your Altira Macau property; please advise. Additionally, tell us what consideration you gave to reassessing the land concession contracts related to your Altira Macau property in December 2013 given the land grant for such property was amended at that time. Further, detail the specific factors that changed on October 1 , 2015 for you to conclude that the amortization period for land use rights related to Altira Macau were extended to 40 years on that date, but not in December 2013. You may contact Mark Rakip, Staff Accountant at 202.551.3573 or me at 202.551.3429 if you have questions regarding comments on the financial s tatements and related matters. Sincerely, /s/ Kristi Marrone Kristi Marrone Staff Accountant Office of Re al Estate and Commodities