SEC Comment Letter for Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640) (MLCO) — Sep 19, 2016
Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640)
Date: Sept. 19, 2016 · CIK: 0001381640 · Accession: 0000000000-16-093326
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3233 September 1 6, 2016 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 year ended December 31, 2015 Filed April 12, 2016 File No. 1 -33178
Dear Mr. Davis:
We have reviewed your August 31, 2016 response to our comment letter and have the following comment s. 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 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 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. Unless we note otherwise, our references to prior comments are to comments in our July 15, 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 comment 1b. Please provide to us your in ternal construction timeline supporting your conclusion that the material terms of the land concession contracts could be reasonably expected to be completed by the required 2018 deadlines. In your response, specifically detail for us the additional const ruction completed for the City of Dreams and Studio City projects from October 2015 through
Geoffrey Davis Melco Crown Entertainment Limited September 1 6, 2016 Page 2
the date of your next response and compare this to your construction timeline as of October 2015. 2. We note your response to prior comment 1c and reissue the comment in part . Please tell us the specific factors th at caused the company to form the view in October 2015, and not prior , that the outstanding administrative procedures required to enable automatic renewal of the Altira Macau land concession contract c ould be reasonably completed and renewal achieved.
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 September 1 6, 2016 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 year ended December 31, 2015 Filed April 12, 2016 File No. 1 -33178 Dear Mr. Davis: We have reviewed your August 31, 2016 response to our comment letter and have the following comment s. 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 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 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. Unless we note otherwise, our references to prior comments are to comments in our July 15, 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 comment 1b. Please provide to us your in ternal construction timeline supporting your conclusion that the material terms of the land concession contracts could be reasonably expected to be completed by the required 2018 deadlines. In your response, specifically detail for us the additional const ruction completed for the City of Dreams and Studio City projects from October 2015 through Geoffrey Davis Melco Crown Entertainment Limited September 1 6, 2016 Page 2 the date of your next response and compare this to your construction timeline as of October 2015. 2. We note your response to prior comment 1c and reissue the comment in part . Please tell us the specific factors th at caused the company to form the view in October 2015, and not prior , that the outstanding administrative procedures required to enable automatic renewal of the Altira Macau land concession contract c ould be reasonably completed and renewal achieved. 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 Real Estate and Commodities