SEC Comment Letter for Hyatt Hotels Corp (H) (CIK 0001468174) (H) — May 12, 2011
Hyatt Hotels Corp (H) (CIK 0001468174)
Date: May 12, 2011 · CIK: 0001468174 · Accession: 0000000000-11-029856
AI Filing Summary & Sentiment
Reasoning
Letter
May 12, 2011 Mr. Mark S. Hoplamazian President and Chief Executive Officer Hyatt Hotels Corporation 71 South Wacker Drive, 12 th Floor Chicago, IL 60606 Re: Hyatt Hotels Corporation Form 10-K for the Year Ended December 31, 2010 File No. 1-34521
Dear Mr. Hoplamazian: We have reviewed your filings and have the following comments. In our comments, we ask you to provide us with information so we may better underst and your disclosure. Please respond to this letter via EDGAR within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2010
General
1. Please tell us how you determined you are not required to submit elec tronically and post on your corporate Web site, Inte ractive Data Files pursuant to Rule 405 of Regulation S- T. Refer to Item 601(b)(101) of Regulation S-K.
Item 2. Properties, page 55
2. In future filings, please revi se to distinguish between c onsolidated and unconsolidated properties and to distinguis h between properties accounted for as capital and operating leases.
Mr. Mark S. Hoplamazian Hyatt Hotels Corporation May 12, 2011 Page 2
Item 7. Management’s Discussion and Anal ysis of Financial Condition…, page 66
Comparable Hotels, page 70
3. We note your disclosure about the properties that represent “comparable systemwide hotels” and “comparable operated hotels.” In future periodic reports, identify the properties that have been removed from th e comparable hotel pool in the most recent period.
Results of Operations, page 80
4. We note your disclosure on page 80 about your “significant renovations.” In future periodic reports, please provide quantitative disclosure of any material development costs. Liquidity and Capital Resources, page 91
Capital Expenditures, page 94
5. Please quantify for us the amount of payr oll and other general and administrative expenses capitalized or deferred in each of the three years ended December 31, 2010, for maintenance, enhancements to existing prope rties, and investment in new facilities. Letters of Credit, page 96
6. In future periodic reports, pleas e provide disclosure regardi ng average interest rates and maturity of the letters of credit directly with financial institutions.
Item 15. Exhibits and Financia l Statement Schedules, page 110
7. Please tell us how you determined you were not required to include the schedule of real estate and accumulated depreciation under Rule 12-28 of Regulation S-X. Refer to SAB Topic 7C. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. 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 comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
Mr. Mark S. Hoplamazian Hyatt Hotels Corporation May 12, 2011 Page 3
• staff comments or changes to disclosure in response to staff comments do not foreclose the 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 federa l securities laws of the United States.
You may contact Jonathan Wiggins at ( 202) 551-3694 or me at (202) 551-3486 if you have questions regarding comments on the financial statements and related matters. Please contact Angela McHale, Attorney-Advisor, at (202) 551-3402 or Sonia Barros, Special Counsel, at (202) 551-3655 with any other questions. Sincerely, Daniel L. Gordon Branch Chief
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May 12, 2011
Mr. Mark S. Hoplamazian President and Chief Executive Officer Hyatt Hotels Corporation 71 South Wacker Drive, 12
th Floor
Chicago, IL 60606
Re: Hyatt Hotels Corporation
Form 10-K for the Year Ended December 31, 2010 File No. 1-34521
Dear Mr. Hoplamazian:
We have reviewed your filings and have the following comments. In our comments, we
ask you to provide us with information so we may better underst and your disclosure.
Please respond to this letter via EDGAR within ten business days by providing the
requested information or by advising us when you will provide the requested response. If you do
not believe our comments apply to your facts and circumstances , please tell us why in your
response.
After reviewing the information you provide in response to these comments, we may
have additional comments. Form 10-K for the Year Ended December 31, 2010
General
1. Please tell us how you determined you are not required to submit elec tronically and post
on your corporate Web site, Inte ractive Data Files pursuant to Rule 405 of Regulation S-
T. Refer to Item 601(b)(101) of Regulation S-K.
Item 2. Properties, page 55
2. In future filings, please revi se to distinguish between c onsolidated and unconsolidated
properties and to distinguis h between properties accounted for as capital and operating
leases.
Mr. Mark S. Hoplamazian
Hyatt Hotels Corporation
May 12, 2011 Page 2
Item 7. Management’s Discussion and Anal ysis of Financial Condition…, page 66
Comparable Hotels, page 70
3. We note your disclosure about the properties that represent “comparable systemwide hotels” and “comparable operated hotels.” In future periodic reports, identify the
properties that have been removed from th e comparable hotel pool in the most recent
period.
Results of Operations, page 80
4. We note your disclosure on page 80 about your “significant renovations.” In future
periodic reports, please provide quantitative disclosure of any material development costs.
Liquidity and Capital Resources, page 91
Capital Expenditures, page 94
5. Please quantify for us the amount of payr oll and other general and administrative
expenses capitalized or deferred in each of the three years ended December 31, 2010, for
maintenance, enhancements to existing prope rties, and investment in new facilities.
Letters of Credit, page 96
6. In future periodic reports, pleas e provide disclosure regardi ng average interest rates and
maturity of the letters of credit directly with financial institutions.
Item 15. Exhibits and Financia l Statement Schedules, page 110
7. Please tell us how you determined you were not required to include the schedule of real
estate and accumulated depreciation under Rule 12-28 of Regulation S-X. Refer to SAB
Topic 7C. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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 comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
Mr. Mark S. Hoplamazian
Hyatt Hotels Corporation
May 12, 2011 Page 3
• staff comments or changes to disclosure in response to staff comments do not foreclose
the 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 federa l securities laws of the United States.
You may contact Jonathan Wiggins at ( 202) 551-3694 or me at (202) 551-3486 if you
have questions regarding comments on the financial statements and related matters. Please
contact Angela McHale, Attorney-Advisor, at (202) 551-3402 or Sonia Barros, Special Counsel,
at (202) 551-3655 with any other questions.
Sincerely,
Daniel L. Gordon Branch Chief