Liquidity & Capital Resources

Staff comment: We note your accounting policy disclosure on page 70 indicating that you depreciate aircraft over 25 years while using an estimated residual value of 20 percent, although also indicating that for "certain Airbus A320 airframes" you are using a longer period as part of your "capital-light growth" initiative, although without specifying the number of aircraft or the extended range being utilized for depreciation. You provide disclosures on page 13 under the Operations and Cost Structure heading, and on page 43 within the Overview section of MD&A, associating this fleet management initiative with recent plans to secure your financial future and navigate near-term demand volatility. However, on… letter →

Staff comment: Please provide a period to period comparative analysis and discussion of changes in cash flows from operating activities, including changes in working capital components, in your annual and interim period reports. In doing so, explain the underlying business reasons and implications of material changes between periods to provide investors with an understanding of variability and potential trends in cash flows. Ensure your discussion and analysis is not merely a recitation of changes evident from the consolidated statements of cash flows. Refer to Item 303(a) and (b) of Regulation S-K and SEC Release No. 33-8350. letter →

Staff comment: In your February 5, 2026 earnings call, management spent time discussing some "short- term industry-wide policy headwinds" that are impacting client budgets and advertising booking rates for pharmaceutical companies. Management also indicated that higher AI infrastructure investment has impacted the results through the period ended December 31, 2025 and is expected to continue impacting future periods. Please show us how you intend to revise to address (and quantify where possible) any known material trends, demands, commitments, events or uncertainties that are reasonably likely to result in a material change to your liquidity or results from operations. Please refer to Item 303(c) of… letter →

Staff comment: We note your disclosure, here and on page 16, that deposit inflows are a primary source of funds. We also note your disclosure that First Federal of Kentucky entered into a formal written agreement with the OCC and that the OCC has imposed individual minimum capital requirements. To the extent that these items remain in place, please revise your future filings, here or elsewhere as appropriate, to clarify whether they affect the ability of any of your entities to be considered well-capitalized, regardless of actual capital levels. If so, disclose whether you have any restrictions on or waiver requirements for rolling brokered deposits, and quantify any related impact for the periods… letter →

Staff comment: It appears the increase of $82.8 million in cash paid for income taxes, net of refunds, in fiscal 2024 compared to fiscal 2023 is a material item that is not disclosed as a factor in your analysis of changes in operating cash flows. Please discuss all material usages of cash as appropriate. Refer to Item 303(a) and (b) of Regulation S-K. Additionally, quantify each variance factor cited in annual and interim period reports. letter →

Staff comment: We note your revised discussion in the final paragraph on page 1 and the first paragraph on page 2. Please further revise to provide additional context regarding the stated reasons for the bankruptcy, including whether the reasons reflect widely applicable challenges confronting industry participants (such as prohibitive cost, financing concerns, or otherwise). In addition, please provide further disclosure regarding the encumbrances that could not be cleared through the bankruptcy process. We note that your revised disclosures here should provide contextualizing disclosure so that investors can evaluate your decision to pursue these particular assets in the manner described. The Company… letter →

Staff comment: Please revise to provide additional disclosure regarding SOL and your staking plans. For example purposes only: • Disclose your policies and procedures regarding your plans to stake Solana, including how much of your SOL you intend to stake. • Revise to provide greater detail explaining how agreements with staking providers will operate. • If material, add a risk factor addressing any liquidity risks related to your staking plans. • Identify the custodians that hold and will hold your digital assets and disclose the material terms of the custody arrangements, including the amount and limitations of any insurance coverage. letter →