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UPLOAD Filing

Hyatt Hotels Corp
Date: Aug. 20, 2025 · CIK: 0001468174 · Accession: 0000000000-25-008878

Financial Reporting Revenue Recognition Internal Controls

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File numbers found in text: 001-34521

Date
August 20, 2025
Author
Division of
Form
UPLOAD
Company
Hyatt Hotels Corp

Letter

Re: Hyatt Hotels Corporation Form 10-K for the year ended December 31, 2024 Filed February 13, 2025 Form 8-K Filed August 7, 2025 File No. 001-34521 Dear Joan Bottarini:

August 20, 2025

Joan Bottarini Chief Financial Officer Hyatt Hotels Corporation 150 North Riverside Plaza 8th Floor Chicago, IL 60606

We have reviewed your filing and have the following comments.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for the year ended December 31, 2024 Consolidated Statements of Income, page F-5

1. Please present charges related to goodwill impairment in a separate line item in accordance with ASC 350-20-45-2. Note 3. Revenue from Contracts with Customers, page F-27

2. We note that 10% of your $125 million remaining performance obligations will be recognized in within the next 12 months and the remaining thereafter. Please tell us in what periods you expect to recognize the remaining 90% thereafter and how your current disclosures reflect the appropriate time bands for your arrangements. In that regard, please tell us how you considered disclosure around revenue expected to be recognized within 1 year, 2 years etc. Refer to 606-10-50-13(b). August 20, 2025 Page 2

Note 4. Debt and Equity Securities, page F-27

3. We note that the Company recognized a pre-tax gain of $231 million related to the UVC Transaction. Please tell us how the Company applied the guidance in ASC 810- 10-40-5 and provide us with your calculation for measuring the deconsolidation of your controlling financial interest that resulted in the gain and clarify whether the $914 million reduction in goodwill disclosed on page F-44 relates to your accounting for the UVC Transaction. Note 7. Acquisitions and Dispositions, page F-35

4. We note the $336 preliminary value attributed to goodwill associated with the Bahia Principe acquisition that closed on December 27, 2024. We also note from page F-28 that the goodwill associated with VIEs on the consolidated balance sheets as of December 31, 2024 was only $147 million. Please reconcile these amounts. Given the proximity of the Bahia Principe closing date to December 31, 2024, explain any factors that may have contributed to revisions of the preliminary goodwill estimate. Form 8-K filed August 7, 2025 Reconciliation of Non-GAAP Financial Measures, page A-9

5. We note your adjustment of "Fund (surpluses) deficits" in order to arrive at "Adjusted net income attributable to Hyatt Hotels Corporation." Please tell us what consideration you gave to presenting the components of the adjustment on a disaggregated basis. Your response should highlight all factors considered that would support and/or not support such a presentation. 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.

Please contact Ameen Hamady at 202-551-3891 or Kristina Marrone at 202-551-3429 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Real
Estate & Construction

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 August 20, 2025

Joan Bottarini
Chief Financial Officer
Hyatt Hotels Corporation
150 North Riverside Plaza
8th Floor
Chicago, IL 60606

 Re: Hyatt Hotels Corporation
 Form 10-K for the year ended December 31, 2024
 Filed February 13, 2025
 Form 8-K
 Filed August 7, 2025
 File No. 001-34521
Dear Joan Bottarini:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the year ended December 31, 2024
Consolidated Statements of Income, page F-5

1. Please present charges related to goodwill impairment in a separate line
item in
 accordance with ASC 350-20-45-2.
Note 3. Revenue from Contracts with Customers, page F-27

2. We note that 10% of your $125 million remaining performance obligations
will be
 recognized in within the next 12 months and the remaining thereafter.
Please tell us in
 what periods you expect to recognize the remaining 90% thereafter and
how your
 current disclosures reflect the appropriate time bands for your
arrangements. In that
 regard, please tell us how you considered disclosure around revenue
expected to be
 recognized within 1 year, 2 years etc. Refer to 606-10-50-13(b).
 August 20, 2025
Page 2

Note 4. Debt and Equity Securities, page F-27

3. We note that the Company recognized a pre-tax gain of $231 million
related to the
 UVC Transaction. Please tell us how the Company applied the guidance in
ASC 810-
 10-40-5 and provide us with your calculation for measuring the
deconsolidation of
 your controlling financial interest that resulted in the gain and
clarify whether the
 $914 million reduction in goodwill disclosed on page F-44 relates to
your accounting
 for the UVC Transaction.
Note 7. Acquisitions and Dispositions, page F-35

4. We note the $336 preliminary value attributed to goodwill associated
with the Bahia
 Principe acquisition that closed on December 27, 2024. We also note from
page F-28
 that the goodwill associated with VIEs on the consolidated balance
sheets as of
 December 31, 2024 was only $147 million. Please reconcile these amounts.
Given the
 proximity of the Bahia Principe closing date to December 31, 2024,
explain any
 factors that may have contributed to revisions of the preliminary
goodwill estimate.
Form 8-K filed August 7, 2025
Reconciliation of Non-GAAP Financial Measures, page A-9

5. We note your adjustment of "Fund (surpluses) deficits" in order to
arrive at "Adjusted
 net income attributable to Hyatt Hotels Corporation." Please tell us
what consideration
 you gave to presenting the components of the adjustment on a
disaggregated basis.
 Your response should highlight all factors considered that would support
and/or not
 support such a presentation.
 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.

 Please contact Ameen Hamady at 202-551-3891 or Kristina Marrone at
202-551-3429
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
</TEXT>
</DOCUMENT>