View:
March 16, 2006
Mail Stop 4561
By U.S. Mail and facsimile to (214) 756-6979
Mr. Brian O. Casey
President and Chief Executive Officer
Westwood Holdings Group, Inc.
200 Crescent Court, Suite 1200
Dallas, TX 75201
Re: Westwood Holdings Group, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2005
File No. 1-31234
Dear Mr. Casey:
We have reviewed your filings and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments. If you disagree with a comment, we
will
consider your explanation as to why our comment is inapplicable.
Please be as detailed as necessary in your explanation. In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure. After
reviewing this information, we may or may not raise additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
* * * * * * *
Form 10-K filed February 24, 2006
Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies, page F-9
1. We note your disclosure on page F-9 that advisory and trust
fees
are generally payable in advance on a calendar quarter basis and
that
advance payments are deferred and recognized over the periods
services are performed. Please provide us with the following
information:
* quantify the amount of advisory and trust fee deferred revenue
as
of each period presented;
* tell us the line item of your consolidated balance sheets in
which
deferred revenue was presented;
* quantify the extent to which your advisory and trust fees are
payable in advance instead of as incurred; and
* tell us when you generally bill clients in advance for advisory
and
trust fees (e.g. first day of the calendar quarter, last day of
quarter preceeding the calendar quarter billed).
* * * * * * *
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a detailed letter that keys your responses to our
comments and provides any requested supplemental information.
Please
understand that we may have additional comments after reviewing
your
responses to our comments.
We urge all persons who are responsible for the accuracy
and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.
You may contact Lisa Haynes, Staff Accountant at (202) 551-
3424
or me at (202) 551-3492 if you have questions.
Sincerely,
John P. Nolan
Accounting Branch Chief
??
??
??
??
Mr. Brian O. Casey
Westwood Holdings Group, Inc.
March 16, 2006
Page 3