SEC Comment Letter 0000000000-23-013788 to Adverum Biotechnologies, Inc. (ADVM) (CIK 0001501756)
Adverum Biotechnologies, Inc. (ADVM) (CIK 0001501756)
Date: Dec. 18, 2023 · CIK: 0001501756 · Accession: 0000000000-23-013788
AI Filing Summary & Sentiment
File numbers found in text: 001-36579
Letter
United States securities and exchange commission logo December 18, 2023 Linda Rubinstein Chief Financial Officer Adverum Biotechnologies, Inc. 100 Cardinal Way Redwood City , CA Re:Adverum Biotechnologies, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed March 30, 2023 File No. 001-36579 Dear Linda Rubinstein: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 the 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 Fiscal Year Ended December 31, 2022 Notes to Consolidated Financial Statements 5. Leases, page 96 1.Please respond to the following lease related comments: •You disclosed here that you adjusted to eliminate the deferred rent receivable in 2022 because its collectability was determined to be less than probable. Help us understand how you have considered whether such a determination would raise similar concern for the impairment of your right of use lease assets. •Quantify for us and revise future filings to clearly disclose the charges to the statement of operations as a result of lease modifications, as well as their related accounts. This comment also applies to your 2023 10-Q filings. •As a related matter, you disclosed under Item 9A that an immaterial non-cash lease accounting error was identified in previously issued financial statements. Please help us understand the nature and amount of the error, as well as how you have assessed its materiality.
FirstName LastNameLinda Rubinstein Comapany NameAdverum Biotechnologies, Inc. December 18, 2023 Page 2 FirstName LastName Linda Rubinstein Adverum Biotechnologies, Inc. December 18, 2023 Page 2 In closing, 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 Li Xiao at 202-551-4391 or Mary Mast at 202-551-3613 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
December 18, 2023
Linda Rubinstein
Chief Financial Officer
Adverum Biotechnologies, Inc.
100 Cardinal Way
Redwood City , CA
Re:Adverum Biotechnologies, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed March 30, 2023
File No. 001-36579
Dear Linda Rubinstein:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
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
the 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 Fiscal Year Ended December 31, 2022
Notes to Consolidated Financial Statements
5. Leases, page 96
1.Please respond to the following lease related comments:
•You disclosed here that you adjusted to eliminate the deferred rent receivable in 2022
because its collectability was determined to be less than probable. Help us understand
how you have considered whether such a determination would raise similar concern
for the impairment of your right of use lease assets.
•Quantify for us and revise future filings to clearly disclose the charges to the
statement of operations as a result of lease modifications, as well as their related
accounts. This comment also applies to your 2023 10-Q filings.
•As a related matter, you disclosed under Item 9A that an immaterial non-cash lease
accounting error was identified in previously issued financial statements. Please help
us understand the nature and amount of the error, as well as how you have
assessed its materiality.
FirstName LastNameLinda Rubinstein
Comapany NameAdverum Biotechnologies, Inc.
December 18, 2023 Page 2
FirstName LastName
Linda Rubinstein
Adverum Biotechnologies, Inc.
December 18, 2023
Page 2
In closing, 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 Li Xiao at 202-551-4391 or Mary Mast at 202-551-3613 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences