SEC Comment Letter for Hilton Worldwide Holdings Inc. (HLT) (CIK 0001585689) (HLT) — Mar 17, 2017
Hilton Worldwide Holdings Inc. (HLT) (CIK 0001585689)
Date: March 17, 2017 · CIK: 0001585689 · Accession: 0000000000-17-008976
AI Filing Summary & Sentiment
Letter
Mail Stop 3233 March 17, 201 7 Via E -mail Mr. Kevin J. Jacobs Chief Financial Officer Hilton Worldwide Holdings Inc. 7930 Jones Branch Drive, Suite 1100 McLean , VA 22102
Re: Hilton Worldwide Holdings Inc. Form 10-K for the fiscal year ended December 31, 2016 Filed February 15, 201 7 File No. 1-36243
Dear Mr. Jacobs :
We have reviewed your filing an d have the following comment s. In some of our comment s, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to our comment s 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 comment s apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to our comment s, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 201 6
Item 7. Management’s Discussio n and Analysis of Financial Cond ition and Results of Operations
RevPAR, page 47
1. You disclose that a currency neutral basis is when all periods use the same exchange rates. Please revise future filings to clarify which period’s exchange rate is used.
Consolidated Financial Statements, page 73
2. Please tell us how you determined it was not necessary to classify the assets and liabilities of Park and HGV as held for sale as of December 31, 2016. Further, please
Kevin J. Jacobs Hilton Worldwide Holdings Inc. March 17, 201 7 Page 2
tell us how you determined it was not neces sary to reclassify the Park and HGV results of operations as discontinued operations for the periods presented. Please refer to ASC 205 -20-45.
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 Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 - 3295 with any questions.
Sincerely,
/s/ Jennifer Monick
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Mail Stop 3233
March 17, 201 7
Via E -mail
Mr. Kevin J. Jacobs
Chief Financial Officer
Hilton Worldwide Holdings Inc.
7930 Jones Branch Drive, Suite 1100
McLean , VA 22102
Re: Hilton Worldwide Holdings Inc.
Form 10-K for the fiscal year ended December 31, 2016
Filed February 15, 201 7
File No. 1-36243
Dear Mr. Jacobs :
We have reviewed your filing an d have the following comment s. In some of our
comment s, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to our comment s 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
comment s apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to our comment s, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 201 6
Item 7. Management’s Discussio n and Analysis of Financial Cond ition and Results of
Operations
RevPAR, page 47
1. You disclose that a currency neutral basis is when all periods use the same exchange
rates. Please revise future filings to clarify which period’s exchange rate is used.
Consolidated Financial Statements, page 73
2. Please tell us how you determined it was not necessary to classify the assets and
liabilities of Park and HGV as held for sale as of December 31, 2016. Further, please
Kevin J. Jacobs
Hilton Worldwide Holdings Inc.
March 17, 201 7
Page 2
tell us how you determined it was not neces sary to reclassify the Park and HGV
results of operations as discontinued operations for the periods presented. Please
refer to ASC 205 -20-45.
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 Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 -
3295 with any questions.
Sincerely,
/s/ Jennifer Monick
Jennifer Monick
Assistant Chief Accountant
Office of Real Estate & -
Commodities