SEC Comment Letter for DigitalBridge Group, (DBRG) — Apr 17, 2018
DigitalBridge Group, Inc.
Date: April 17, 2018 · CIK: 0001679688 · Accession: 0000000000-18-011641
AI Filing Summary & Sentiment
File numbers found in text: 001-37980
Letter
Mailstop 3233 April 17, 201 8 Via E-mail Mr. Darren J. Tangen Chief Financial Officer Colony NorthStar, Inc. 515 South Flower Street, 44th Floor Los Angeles, CA 90071 Form 8 -K Filed March 1, 201 8 File No. 001-37980
Re: Colony NorthStar, Inc. Form 10-K for the fiscal year e nded December 31, 201 7 Filed March 1, 201 8 File No. 001 -37980
Dear Mr. Tangen :
We have limited our review of your filing s 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 business days by providing the requested information or advise us as soon as p ossible 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 c omments, we may have additional comments.
Form 8 -K filed March 1, 2018
Exhibits 99.1 and 99.2
1. We note you present “EBITDAR ” as part of your TTM coverage ratios in your quarterly earnings release and supplemental package . It appears such a measure represents a non- GAAP financial measure. Please clarify how you have complied with the disclosure requirements outlined within Item 10(e) of Reg ulation S -K.
Mr. Darren J. Tangen Colony NorthStar, Inc. April 17, 201 8 Page 2
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 Jeffrey Lewis, Staff Accountant, at (20 2) 551 -6216 or the undersigned at (202) 551-3486 with any questions.
Sincerely,
/s/ Daniel L. Gordon
Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities
Show Raw Text
Mailstop 3233
April 17, 201 8
Via E-mail
Mr. Darren J. Tangen
Chief Financial Officer
Colony NorthStar, Inc.
515 South Flower Street, 44th Floor
Los Angeles, CA 90071
Re: Colony NorthStar, Inc.
Form 10-K for the fiscal year e nded December 31, 201 7
Filed March 1, 201 8
File No. 001 -37980
Form 8 -K
Filed March 1, 201 8
File No. 001-37980
Dear Mr. Tangen :
We have limited our review of your filing s 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 business days by providing the requested
information or advise us as soon as p ossible 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 c omments, we may have additional comments.
Form 8 -K filed March 1, 2018
Exhibits 99.1 and 99.2
1. We note you present “EBITDAR ” as part of your TTM coverage ratios in your quarterly
earnings release and supplemental package . It appears such a measure represents a non-
GAAP financial measure. Please clarify how you have complied with the disclosure
requirements outlined within Item 10(e) of Reg ulation S -K.
Mr. Darren J. Tangen
Colony NorthStar, Inc.
April 17, 201 8
Page 2
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 Jeffrey Lewis, Staff Accountant, at (20 2) 551 -6216 or the undersigned
at (202) 551-3486 with any questions.
Sincerely,
/s/ Daniel L. Gordon
Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities