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MGMMGM Resorts

Consumer discretionary · Hotels · NYSE
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SEC comment letters, last 20 years

1 review of MGM's filings by SEC staff

UPLOAD and CORRESP
ReviewsRead ↓
1
latest letter 2022-09-19
Questions asked
2
each answered in the company's own letter
No closing letter
0
reviews without a letter saying the staff completed it

When the SEC's staff reviews a filing, it writes to the company with numbered questions, and the company answers each one in a letter. SEC publishes the exchange once the review is over, at least 20 business days later. A question is not an accusation; most reviews end with the company adding detail to its next filing.

Form 10-K for the Fiscal Year Ended December 31, 2021

2022-09-19 to 2022-09-26 · 2 questions · 1 letter from the SEC, 1 from the company
Review closed 2022-09-26
Non-GAAP measuresKey metrics
Second Quarter 2022 Financial Highlights · Consolidated Results, page 2
SEC asked (1)
We note your disclosure that adjusted EBITDAR information is a valuation metric and should not be used as an operating metric. We further note your presentation of Adjusted EBITDAR margin. Please tell us what consideration you gave to your inclusion of this margin resulting in Adjusted EBITDAR also being viewed a measure of your operating performance.
MGM answered
In future filings, the Company will revise its presentation to remove Adjusted EBITDAR margin. Read in the reply ↗
In its next report

First report after the company's reply of 2022-09-22: 10-Q filed 2022-11-02 ↗, against the 10-Q filed 2022-08-03 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Adjusted Diluted Earnings Per Share, page 3
SEC asked (2)
We note your adjustment for loss (gain) related to equity investments to arrive at adjusted diluted earnings per share. Please tell us the nature of this adjustment and how it is derived.
MGM answered
Loss (gain) related to equity investments reflects the net unrealized loss (gain) relating to equity investments for which the Company has elected the fair value option of ASC 825 and equity investments accounted for under ASC 321 for which there is a readily determinable fair value.

If there are additional comments or questions, please do not hesitate to contact the undersigned at (212) 530-5022. Read in the reply ↗
In its next report

First report after the company's reply of 2022-09-22: 10-Q filed 2022-11-02 ↗, against the 10-Q filed 2022-08-03 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Also in this review: closing letter, 2022-09-26

From the SEC's correspondence on EDGAR: staff letters (form UPLOAD) and company letters (form CORRESP), 8 letters filed since 2020-07-16. Questions and answers are matched by their numbers; topics come from words in each question. The reports are compared word for word (same form, before the first SEC letter against the first report after the company's reply). No AI.

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