Seward & Kissel llp
ONE BATTERY PARK PLAZA
NEW YORK, NEW YORK 10004
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GARY J. WOLFE
PARTNER (212) 574-1223 wolfe@sewkis.com |
TELEPHONE: (212) 574-1200
FACSIMILE: (212) 480-8421
WWW.SEWKIS.COM
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901 K STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE: (202) 737-8833
FACSIMILE: (202) 737-5184
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Re:
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Ship Finance International LTD
Form 20-F for the Year Ended December 31, 2017 Form 6-K furnished February 28, 2018 File No. 001-32199 |
a. |
The Company confirms that this is a metric figure rather than a non-GAAP measure, and essentially represents amounts billable by the Company and its 100% owned unconsolidated subsidiaries.
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b. |
The description of this will be changed from "Charter hire revenue" to "Charter hire" to avoid any connection to any GAAP or non-GAAP measure.
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c. |
Total charter hire will be split in the Selected Key Data table between the Company and its 100% owned unconsolidated subsidiaries and totaled.
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d. |
A footnote will be added to explain what Charter hire represents.
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a. |
The Company confirms that Adjusted EBITDA is used by the Company as a non-GAAP liquidity rather than a performance measure and as such will be reconciled to "Net cash provided by operating activities" as presented in the cashflow statement rather than "Net income" as presented in the Income Statement.
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b. |
Adjusted EBITDA will be separately presented for the Company and its 100% owned unconsolidated subsidiaries and will not be totaled.
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a. |
"Revenue classified as repayment of investment in finance leases" as described in historic press releases will be removed from the income statement of both the Company and Associates and a footnote explanation will be added.
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b. |
"Charter Revenues – finance lease" will be presented net of charter hire treated as "Repayment of investment in finance leases".
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a. |
A description of non-GAAP measures used by the Company will be added to the Company's press releases making clear that they do not represent GAAP measures.
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b. |
Each non-GAAP measure described will include an explanation of why its presentation and inclusion is important to the Company and its investors.
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c. |
The Company will ensure that GAAP measures will be presented more prominently than any non-GAAP measure in the Company's press releases going forward.
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Sincerely
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/s/ Gary J. Wolfe
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Gary J. Wolfe
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cc:
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Beverly A. Singleton
Claire Erlanger Division of Corporate Finance Securities and Exchange Commission Harald Gurvin
Chief Financial Officer Ship Finance Management AS |