- Map: Station Casinos and the Las Vegas Locals Market (last updated 10/31/2016)
- Letter to Nevada gaming regulators concerning Deutsche Bank’s most recent legal and regulatory developments and its expansion of ownership in Nevada casinos (5/19/2016)
- Letter to the SEC regarding questions concerning the audited financial statements of Red Rock Resorts (4/15/16)
- Letter to the Federal Reserve and Federal Deposit Insurance Corporation regarding information missing from Deutsche Bank’s public “living will” (3/15/16)
- Letter to Nevada Governor Brian Sandoval re the rushed approval of the Red Rock Resorts IPO by state gaming regulators (3/1/16). We want to “illustrate the challenges Nevada faces in regulating a ‘too-big-to-regulate’ significant owner of one of the major gaming companies in Las Vegas.”
- Letter to Deutsche Bank urging it to dispose of its non-core casino asset through the Station Casinos/Red Rock Resorts IPO (2/11/16). “Selling off [the bank’s] casino stake now should help boost investor confidence in the bank’s willingness and ability to deal effectively with its legacy issues and non-core assets.”
- Letter to SEC re Information Missing from Red Rock Resorts, Inc.’s IPO Registration Filings (1/26/16). “We believe additional disclosure on the subjects we describe below is necessary to ensure prospective shareholders have complete and detailed information about the proposed public offering by the registrant.”
- Comment letter re SEC Rule 3-05, Financial Statements of Businesses Acquired or to be Acquired (11/30/15). We ask the Commission to consider three specific amendments to Rule 3-05. We have arrived at our suggestions after reviewing recent filings by Station Casinos LLC and Station Casinos Corp. We think investors would find it difficult to evaluate the proposed $460-million purchase price of Fertitta Entertainment LLC as neither registrant has provided historical financials of the target.
- Summary of letter to SEC requesting review of Station Casinos Corp.’s omissions in October 13, 2015, registration filing (11/3/15). We believe that in its preliminary prospectus, Station Casinos omitted disclosure of ongoing and recent investigations into a major owner of the company, Deutsche Bank AG, which, through its wholly-owned subsidiary German American Capital Corporation (GACC), owns 25 percent of the equity interests in Station Casinos LLC and could become a significant shareholder of Station Casinos Corp. upon the completion of the IPO.
