SEC Comment Letter 0000000000-24-005367 to Xenia Hotels & Resorts, Inc. (XHR) (CIK 0001616000) (XHR)
Xenia Hotels & Resorts, Inc. (XHR) (CIK 0001616000)
Date: May 13, 2024 · CIK: 0001616000 · Accession: 0000000000-24-005367
AI Filing Summary & Sentiment
File numbers found in text: 001-36594
Letter
United States securities and exchange commission logo May 13, 2024 Atish Shah Executive Vice President, Chief Financial Officer and Treasurer Xenia Hotels & Resorts, Inc. 200 S. Orange Avenue, Suite 2700 Orlando, FL 32801 Re:Xenia Hotels & Resorts, Inc. Form 10-K for the year ended December 31, 2023 Form 8-K filed May 2, 2024 File No. 001-36594 Dear Atish Shah: 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 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 8-K filed May 2, 2024 Exhibit 99.1 Operating Results, page 2 1.We note your presentation of Same-Property Hotel Net Income throughout your earnings release. It does not appear that you have identified this measure as a non-GAAP measure. Please clarify for us how you determined this measure is not a non-GAAP measure. In your response, please provide us with qualitative and quantitative information to understand the differences between GAAP Net income of $8,967,000 and Same- Property Hotel Net Income of $36,666,000. 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 Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with
FirstName LastNameAtish Shah Comapany NameXenia Hotels & Resorts, Inc. May 13, 2024 Page 2 FirstName LastName Atish Shah Xenia Hotels & Resorts, Inc. May 13, 2024 Page 2 any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
May 13, 2024
Atish Shah
Executive Vice President, Chief Financial Officer and Treasurer
Xenia Hotels & Resorts, Inc.
200 S. Orange Avenue, Suite 2700
Orlando, FL 32801
Re:Xenia Hotels & Resorts, Inc.
Form 10-K for the year ended December 31, 2023
Form 8-K filed May 2, 2024
File No. 001-36594
Dear Atish Shah:
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 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 8-K filed May 2, 2024
Exhibit 99.1
Operating Results, page 2
1.We note your presentation of Same-Property Hotel Net Income throughout your earnings
release. It does not appear that you have identified this measure as a non-GAAP
measure. Please clarify for us how you determined this measure is not a non-GAAP
measure. In your response, please provide us with qualitative and quantitative information
to understand the differences between GAAP Net income of $8,967,000 and Same-
Property Hotel Net Income of $36,666,000.
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 Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with
FirstName LastNameAtish Shah
Comapany NameXenia Hotels & Resorts, Inc.
May 13, 2024 Page 2
FirstName LastName
Atish Shah
Xenia Hotels & Resorts, Inc.
May 13, 2024
Page 2
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction