SEC Comment Letter 0000000000-24-003919 to Air Products & Chemicals, Inc. (APD) (CIK 0000002969) (APD)
Air Products & Chemicals, Inc. (APD) (CIK 0000002969)
Date: April 11, 2024 · CIK: 0000002969 · Accession: 0000000000-24-003919
AI Filing Summary & Sentiment
File numbers found in text: 001-04534
Referenced dates: April 8, 2024
Letter
United States securities and exchange commission logo April 11, 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 Response Letter Dated April 8, 2024 File No. 001-04534 Dear Melissa N. Schaeffer: We have reviewed your April 8, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our March 13, 2023 letter. Form 10-K for Fiscal Year Ended September 30, 2023 5. Acquisitions, page 73 1.We note your response to our prior comment, including the expanded disclosures you intend to provide in future filings. Please further expand these disclosures to include your conclusion that the repurchase price with consideration of time value of money exceeds the original purchase price, as discussed in the first paragraph on page 3 of your response letter, as this analysis forms the basis of your accounting for these transactions. Please ensure that your disclosures include consideration of the allocation of the contractual cash inflows to be received from UNG on a monthly basis between the repurchase price and compensation for your services provided under the agreements for purposes of this analysis, if correct.
FirstName LastNameMelissa N. Schaeffer Comapany NameAir Products & Chemicals, Inc. April 11, 2024 Page 2 FirstName LastName Melissa N. Schaeffer Air Products & Chemicals, Inc. April 11, 2024 Page 2 Please contact Tracey Houser at 202-551-3736 or Nudrat Salik at 202-551-3692 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
April 11, 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
Response Letter Dated April 8, 2024
File No. 001-04534
Dear Melissa N. Schaeffer:
We have reviewed your April 8, 2024 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our March 13, 2023
letter.
Form 10-K for Fiscal Year Ended September 30, 2023
5. Acquisitions, page 73
1.We note your response to our prior comment, including the expanded disclosures you
intend to provide in future filings. Please further expand these disclosures to include your
conclusion that the repurchase price with consideration of time value of money exceeds
the original purchase price, as discussed in the first paragraph on page 3 of your response
letter, as this analysis forms the basis of your accounting for these transactions. Please
ensure that your disclosures include consideration of the allocation of the contractual cash
inflows to be received from UNG on a monthly basis between the repurchase price and
compensation for your services provided under the agreements for purposes of this
analysis, if correct.
FirstName LastNameMelissa N. Schaeffer
Comapany NameAir Products & Chemicals, Inc.
April 11, 2024 Page 2
FirstName LastName
Melissa N. Schaeffer
Air Products & Chemicals, Inc.
April 11, 2024
Page 2
Please contact Tracey Houser at 202-551-3736 or Nudrat Salik at 202-551-3692 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services