SEC Comment Letter for EQT Corp (EQT) (CIK 0000033213) (EQT) — Sep 3, 2014
EQT Corp (EQT) (CIK 0000033213)
Date: Sept. 3, 2014 · CIK: 0000033213 · Accession: 0000000000-14-044123
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-03551
Letter
September 3, 201 4 Via E-mail Mr. Philip P. Conti Chief Financial Officer EQT Corporation 625 Liberty Avenue Pittsburgh, Pennsylvania 15222
Re: EQT Corporation Form 10-K for Fiscal Year End ed December 31, 201 3 Filed on February 2 0, 2014 File No. 001-03551
Dear Mr. Conti :
We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our co mments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have addi tional comments.
Annual Report on Form 10 -K for the Fiscal Year Ended December 31, 2013
Properties, page 22
Natural gas, BTU premium, NGL and crude oil production and pricing, page 23
1. Please provide , as supplemental information , a reconcili ation of total natural gas and oil production quantities for 2013 per the presentations on pages 25 and 109 to corresponding amounts appearing in the tables on pages 34 and 36.
2. The presentation on page 25 presents production quantities on a combined basis , while the presentations on pages 34 and 36 appear as though they may include volumes in excess of your actual production. In view of this, explain to us which of the presentations on pages 25, 34 or 36 is intended to satisfy the requirements of Item 1204(a) of
Philip P. Conti EQT Corporation September 3 , 2014 Page 2
Regulation S -K. In this regard, note that you are required disclose production, by final product sold, on an “as sold” basis.
Form 8 -K dated July 24, 2014
Exhibit 99.1
3. The financial measures provided in Exhibit 99.1 include a presentation of adjusted cash flow per share. Please note that presentation of cash flow per share is not consistent with the guidance in Compliance and Disclosure Interpretation 102.05 or Financia l Reporting Codification 202.04. Please revise your presentation accordingly.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities E xchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made .
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of t he United States.
You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or me, at (202) 551 -3489 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Brad Skinner
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September 3, 201 4 Via E-mail Mr. Philip P. Conti Chief Financial Officer EQT Corporation 625 Liberty Avenue Pittsburgh, Pennsylvania 15222 Re: EQT Corporation Form 10-K for Fiscal Year End ed December 31, 201 3 Filed on February 2 0, 2014 File No. 001-03551 Dear Mr. Conti : We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our co mments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have addi tional comments. Annual Report on Form 10 -K for the Fiscal Year Ended December 31, 2013 Properties, page 22 Natural gas, BTU premium, NGL and crude oil production and pricing, page 23 1. Please provide , as supplemental information , a reconcili ation of total natural gas and oil production quantities for 2013 per the presentations on pages 25 and 109 to corresponding amounts appearing in the tables on pages 34 and 36. 2. The presentation on page 25 presents production quantities on a combined basis , while the presentations on pages 34 and 36 appear as though they may include volumes in excess of your actual production. In view of this, explain to us which of the presentations on pages 25, 34 or 36 is intended to satisfy the requirements of Item 1204(a) of Philip P. Conti EQT Corporation September 3 , 2014 Page 2 Regulation S -K. In this regard, note that you are required disclose production, by final product sold, on an “as sold” basis. Form 8 -K dated July 24, 2014 Exhibit 99.1 3. The financial measures provided in Exhibit 99.1 include a presentation of adjusted cash flow per share. Please note that presentation of cash flow per share is not consistent with the guidance in Compliance and Disclosure Interpretation 102.05 or Financia l Reporting Codification 202.04. Please revise your presentation accordingly. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities E xchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made . In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of t he United States. You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or me, at (202) 551 -3489 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Brad Skinner Brad Skinner Senior Assistant Chief Accountant cc: Theresa Bone