The SEC takes another roll of the dice at Las Vegas Sands…

May 13, 2008

Comment letters can often be difficult to get a handle on. Some people, like my friends at Disclosure Insight, (formerly SEC Insight) put a lot of credence in them. Others, say they’re interesting, but not particularly informative.

I was thinking about this because late Friday, Las Vegas Sands (LVS) filed this 10Q which noted that it had recently received a comment letter from the SEC. But other than noting that it was for the 2007 10K, there simply weren’t enough details to make a call.

Part of the problem is that the rules regarding comment letters are a bit blurry. Companies aren’t required to disclose their existence and even when they do, by the time the letter becomes available on the SEC site, it’s after the investigation has been completed. Indeed, SEC Insight’s model was to find comment letters before they became publicly available via Freedom of Information requests, and make that information available to its subscribers. Earlier today, they announced that they were making five years worth of that information available for free.

At Las Vegas Sands, the most recent comment letter comes on the heels of other comment letters the company received last year over questions of executive compensation. Those letters — there’s six in all dating back to last fall — appear to be similar to the letters sent to lots of other companies last year. Las Vegas Sand’s response to the first letter is here.

What’s interesting with those earlier letters is that the company never disclosed their existence. So why did they choose to do so with the more recent letter? Either they’ve gotten on the disclosure bandwagon or this letter is a bit more serious than questions over executive compensation.

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