SEC Comment Letter 0000000000-24-008035 to Yum China Holdings, Inc. (YUMC)
Yum China Holdings, Inc.
Date: July 16, 2024 · CIK: 0001673358 · Accession: 0000000000-24-008035
AI Filing Summary & Sentiment
Letter
July 16, 2024 Joey Wat Chief Executive Officer Yum China Holdings, Inc. 101 East Park Boulevard, Suite 805 Plano, TX 75074 Re:Yum China Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 1-37762 Dear Joey Wat: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). 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 Fiscal Year Ended December 31, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 66 1.Wherever you present Restaurant margin, please also disclose with equal or greater prominence, the most directly comparable financial measure or measures calculated and presented in accordance with GAAP. Refer to Item 10(e)(1)(i)(A) of Regulation S-K. 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.
July 16, 2024 Page 2 Please contact Ta Tanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-3336 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Joseph Chan, Chief Legal Officer
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July 16, 2024
Joey Wat
Chief Executive Officer
Yum China Holdings, Inc.
101 East Park Boulevard, Suite 805
Plano, TX 75074
Re:Yum China Holdings, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 1-37762
Dear Joey Wat:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
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 Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 66
1.Wherever you present Restaurant margin, please also disclose with equal or greater
prominence, the most directly comparable financial measure or measures calculated and
presented in accordance with GAAP. Refer to Item 10(e)(1)(i)(A) of Regulation S-K.
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.
July 16, 2024
Page 2
Please contact Ta Tanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-3336
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Joseph Chan, Chief Legal Officer