SEC Comment Letter for Hyatt Hotels Corp (H) (CIK 0001468174) (H) — Aug 7, 2018
Hyatt Hotels Corp (H) (CIK 0001468174)
Date: Aug. 7, 2018 · CIK: 0001468174 · Accession: 0000000000-18-024408
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3233 August 7, 2018 Via E -Mail Elizabeth Bauer Senior Vice President, Corporate Controller and Chie f Accounting Officer Hyatt Hotels Corporation 150 North Riverside Plaza, 8th Floor Chicago, IL 60606
Re: Hyatt Hotels Corporation Form 10-K for the fiscal year ended December 31, 2017 Filed February 15, 2018 File No. 1 -34521
Dear Ms. Bauer :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 informa tion 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 .
Form 10 -K for the fiscal year ended December 31, 2017
Note 15. Stockholders’ Equity and Comprehensive Loss
Accumulated Other Comprehensive Loss , page F -43 1. We note your convertible redeemable preferred shares of Playa were redeemed during 2017. Please clarify for us if you had any unrealized gains or losses that were recorded in accumulated other comprehensive income prior to the redemption. To the extent you had unrealized gains or losses, please tell us how you determined it was not nec essary to reflect a reclassification of these unrealized gains or losses in the amounts reclassified from accumulated other comprehensive income column in your table on page F -43. Please refer to ASC 220 -10.
Elizabeth Bauer Hyatt Hotels Corporation August 7, 2018 Page 2
Form 8 -K filed July 31 , 2018
Exhibit 99.1
Segment Financial Summary 2. We note your tabular disclosure of adjusted revenues. This measure appears to be a non - GAAP measure. In future earnings releases, please reconcile adjusted revenues to the most directly comparable GAAP measure. Further, please d isclose why this measure provides useful information to investors. Please refer to Item 10(e) of Regulation S -K.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Mark Rakip, Staff Accountant at 202.551. 3573 or the undersigned at 202.551.3295 with any questions.
Sincerely,
/s/ Jennifer Monick
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Mailstop 3233 August 7, 2018 Via E -Mail Elizabeth Bauer Senior Vice President, Corporate Controller and Chie f Accounting Officer Hyatt Hotels Corporation 150 North Riverside Plaza, 8th Floor Chicago, IL 60606 Re: Hyatt Hotels Corporation Form 10-K for the fiscal year ended December 31, 2017 Filed February 15, 2018 File No. 1 -34521 Dear Ms. Bauer : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 informa tion 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 . Form 10 -K for the fiscal year ended December 31, 2017 Note 15. Stockholders’ Equity and Comprehensive Loss Accumulated Other Comprehensive Loss , page F -43 1. We note your convertible redeemable preferred shares of Playa were redeemed during 2017. Please clarify for us if you had any unrealized gains or losses that were recorded in accumulated other comprehensive income prior to the redemption. To the extent you had unrealized gains or losses, please tell us how you determined it was not nec essary to reflect a reclassification of these unrealized gains or losses in the amounts reclassified from accumulated other comprehensive income column in your table on page F -43. Please refer to ASC 220 -10. Elizabeth Bauer Hyatt Hotels Corporation August 7, 2018 Page 2 Form 8 -K filed July 31 , 2018 Exhibit 99.1 Segment Financial Summary 2. We note your tabular disclosure of adjusted revenues. This measure appears to be a non - GAAP measure. In future earnings releases, please reconcile adjusted revenues to the most directly comparable GAAP measure. Further, please d isclose why this measure provides useful information to investors. Please refer to Item 10(e) of Regulation S -K. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Mark Rakip, Staff Accountant at 202.551. 3573 or the undersigned at 202.551.3295 with any questions. Sincerely, /s/ Jennifer Monick Jennifer Monick Assistant Chief Accountant Office of Real Estate and Commodities