SEC Comment Letter for Four Corners Property Trust, Inc. (FCPT) (CIK 0001650132) (FCPT) — May 7, 2018
Four Corners Property Trust, Inc. (FCPT) (CIK 0001650132)
Date: May 7, 2018 · CIK: 0001650132 · Accession: 0000000000-18-014064
AI Filing Summary & Sentiment
File numbers found in text: 001-37538
Letter
Mail Stop 3233 May 4, 2018 Via E -mail Gerald R. Morgan Chief Financial Officer Four Corners Property Trust, Inc. 591 Redwood Highway, Suite 1150 Mill Valley, CA 94941
Re: Four Corners Property Trust, Inc. Form 10-K for the fiscal year ended December 31, 2017 Filed February 27, 2018 Form 8 -K filed April 25, 2018 File No. 001-37538
Dear Mr. Morgan :
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 8 -K filed April 25 , 2018
Exhibit 99 .2
1. We note that your calculation of EBITDA on page 16 contains adjustments for items other than interest, taxes, depreciation and amortization. Please revise future supplemental presentations to en sure that measures calculated differently from EBITDA are not characterized as EBITDA. See Question 103.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
2. To the extent EBITDA and EBITDA (cash rent) are presented in future f ilings, p lease provide all disclosures required by Item 10(e)(1)(i) of Regulation S -K, including a discussion of the reasons why management believes the se measures provide useful
Gerald R. Morgan Four Corners Property T rust, Inc. May 4, 2018 Page 2
information to investors and to the extent material, additional purposes for which they are used by management.
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 Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or me at (202) 551 - 3429 with any questions.
Sincerely,
/s/ Kristi Marrone
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Mail Stop 3233 May 4, 2018 Via E -mail Gerald R. Morgan Chief Financial Officer Four Corners Property Trust, Inc. 591 Redwood Highway, Suite 1150 Mill Valley, CA 94941 Re: Four Corners Property Trust, Inc. Form 10-K for the fiscal year ended December 31, 2017 Filed February 27, 2018 Form 8 -K filed April 25, 2018 File No. 001-37538 Dear Mr. Morgan : 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 8 -K filed April 25 , 2018 Exhibit 99 .2 1. We note that your calculation of EBITDA on page 16 contains adjustments for items other than interest, taxes, depreciation and amortization. Please revise future supplemental presentations to en sure that measures calculated differently from EBITDA are not characterized as EBITDA. See Question 103.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. 2. To the extent EBITDA and EBITDA (cash rent) are presented in future f ilings, p lease provide all disclosures required by Item 10(e)(1)(i) of Regulation S -K, including a discussion of the reasons why management believes the se measures provide useful Gerald R. Morgan Four Corners Property T rust, Inc. May 4, 2018 Page 2 information to investors and to the extent material, additional purposes for which they are used by management. 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 Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or me at (202) 551 - 3429 with any questions. Sincerely, /s/ Kristi Marrone Kristi Marrone Staff Accountant Office of Real Estate and Commodities