Form 10-K for the fiscal year ended December 31, 2017
Based on footnote (1), it appears that interest expense related to variable-rate debt that is not subject to an interest rate swap agreement is not included. To the extent material, please revise your disclosures in future periodic reports to discuss the cash requirements for such variable-rate debt. Reference is made to footnote 46 of SEC Interpretive Release
Based on footnote (1), it appears that interest expense related to variable-rate debt that is not subject to an interest rate swap agreement is not included. To the extent material, please revise your disclosures in future periodic reports to discuss the cash requirements for such variable-rate debt. Reference is made to footnote 46 of SEC Interpretive Release 33-8350 “Interpretation: Commission Guidance Regarding Management's Discussion and Analysis of Financial Condition and Results of Operations.”
The Company acknowledges the Staff’s comment and advises the Staff that the Company willRead in the reply ↗Rest of the answer
revise its disclosures in future periodic reports, to the extent material, to discuss the cash requirements for interest related to variable-rate debt that is not subject to an interest rate swap agreement.
We hope that this response satisfactorily addresses the Staff’s comment. If you have any further comments or questions or require any additional information concerning the matters discussed herein, please contact me at (901) 248-4169.
First report after the company's reply of 2018-09-11: 10-Q filed 2018-11-01 ↗, against the 10-Q filed 2018-08-02 ↗.
Tickdelta does not hold the text of both reports, so they are not compared here.
Also in this review: closing letter, 2018-09-12