SEC Comment Letter 0000000000-24-002767 to Air Products & Chemicals, Inc. (APD) (CIK 0000002969) (APD)
Air Products & Chemicals, Inc. (APD) (CIK 0000002969)
Date: March 13, 2024 · CIK: 0000002969 · Accession: 0000000000-24-002767
AI Filing Summary & Sentiment
File numbers found in text: 001-04534
Letter
United States securities and exchange commission logo March 13, 2024 Melissa N. Schaeffer Senior Vice President and Chief Financial Officer Air Products & Chemicals, Inc. 1940 Air Products Boulevard Allentown, Pennsylvania 18106-5500 Re:Air Products & Chemicals, Inc. Form 10-K for Fiscal Year Ended September 30, 2023 File No. 001-04534 Dear Melissa N. Schaeffer: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended September 30, 2023 5. Acquisitions, page 73 1.Regarding the agreement to purchase the natural gas-to-syngas processing facility in Qashqadaryo Province, Uzbekistan, for $1 billion, please provide us with a summary of the material terms of the agreement. Please also provide us with a summary of the analysis you performed in determining that the agreement should be accounted for as a financing arrangement, including the corresponding authoritative literature you considered. Please specifically address your initial accounting as well as ongoing accounting for this transaction. Please also address the need to expand your disclosures.
In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameMelissa N. Schaeffer Comapany NameAir Products & Chemicals, Inc. March 13, 2024 Page 2 FirstName LastName Melissa N. Schaeffer Air Products & Chemicals, Inc. March 13, 2024 Page 2 Please contact Tracey Houser at 202-551-3736 or Nudrat Salik at 202-551-3692 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
March 13, 2024
Melissa N. Schaeffer
Senior Vice President and Chief Financial Officer
Air Products & Chemicals, Inc.
1940 Air Products Boulevard
Allentown, Pennsylvania 18106-5500
Re:Air Products & Chemicals, Inc.
Form 10-K for Fiscal Year Ended September 30, 2023
File No. 001-04534
Dear Melissa N. Schaeffer:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended September 30, 2023
5. Acquisitions, page 73
1.Regarding the agreement to purchase the natural gas-to-syngas processing facility in
Qashqadaryo Province, Uzbekistan, for $1 billion, please provide us with a summary of
the material terms of the agreement. Please also provide us with a summary of the analysis
you performed in determining that the agreement should be accounted for as a financing
arrangement, including the corresponding authoritative literature you considered. Please
specifically address your initial accounting as well as ongoing accounting for this
transaction. Please also address the need to expand your disclosures.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameMelissa N. Schaeffer
Comapany NameAir Products & Chemicals, Inc.
March 13, 2024 Page 2
FirstName LastName
Melissa N. Schaeffer
Air Products & Chemicals, Inc.
March 13, 2024
Page 2
Please contact Tracey Houser at 202-551-3736 or Nudrat Salik at 202-551-3692 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services