SEC Comment Letter for DigitalBridge Group, (DBRG) — Apr 8, 2019
DigitalBridge Group, Inc.
Date: April 8, 2019 · CIK: 0001679688 · Accession: 0000000000-19-006720
AI Filing Summary & Sentiment
File numbers found in text: 001-37980
Letter
April 5, 2019 Mark M. Hedstrom Chief Financial Officer Colony Capital, Inc. 515 South Flower Street 44th Floor Los Angeles, CA 90071 Re:Colony Capital, Inc. Form 10-K for the year ended December 31, 2018 Filed March 1, 2019 File No. 001-37980 Dear Mr. Hedstrom: 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 business days by providing the requested information or advise 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 10-K for the year ended December 31, 2018 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations NOI and EBITDA, page 80 1.We note your calculation of EBITDA contains adjustments for items other than interest, taxes, depreciation and amortization. Please revise in future filings to ensure that measures calculated differently from EBITDA are not characterized as EBITDA. See Question 103.01 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016. This comment also applies to your characterization of EBITDA within your earnings release.
FirstName LastNameMark M. Hedstrom Comapany NameColony Capital, Inc. April 5, 2019 Page 2 FirstName LastName Mark M. Hedstrom Colony Capital, Inc. April 5, 2019 Page 2 Notes to Consolidated Financial Statements 2. Summary of Significant Accounting Policies Business Combinations, page F-15 2.We note your disclosure that no gain or loss is recognized for asset acquisitions unless the fair value of non-cash assets given as consideration differs from the carrying amount of the assets acquired. Please clarify this disclosure for us; in this regard, please address how you determined the carrying amount of the assets acquired in these transactions. 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. You may contact Isaac Esquivel, Staff Accountant, at (202) 551-3395 or Jennifer Monick, Assistant Chief Accountant, at (202) 551-3295 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate and Commodities
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April 5, 2019
Mark M. Hedstrom
Chief Financial Officer
Colony Capital, Inc.
515 South Flower Street
44th Floor
Los Angeles, CA 90071
Re:Colony Capital, Inc.
Form 10-K for the year ended December 31, 2018
Filed March 1, 2019
File No. 001-37980
Dear Mr. Hedstrom:
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 business days by providing the requested
information or advise 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 10-K for the year ended December 31, 2018
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
NOI and EBITDA, page 80
1.We note your calculation of EBITDA contains adjustments for items other than interest,
taxes, depreciation and amortization. Please revise in future filings to ensure that
measures calculated differently from EBITDA are not characterized as EBITDA. See
Question 103.01 of the updated Compliance and Disclosure Interpretations issued on May
17, 2016. This comment also applies to your characterization of EBITDA within your
earnings release.
FirstName LastNameMark M. Hedstrom
Comapany NameColony Capital, Inc.
April 5, 2019 Page 2
FirstName LastName
Mark M. Hedstrom
Colony Capital, Inc.
April 5, 2019
Page 2
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Business Combinations, page F-15
2.We note your disclosure that no gain or loss is recognized for asset acquisitions unless the
fair value of non-cash assets given as consideration differs from the carrying amount of
the assets acquired. Please clarify this disclosure for us; in this regard, please address how
you determined the carrying amount of the assets acquired in these transactions.
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.
You may contact Isaac Esquivel, Staff Accountant, at (202) 551-3395 or Jennifer
Monick, Assistant Chief Accountant, at (202) 551-3295 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities