SEC Comment Letter for GENERAL MILLS INC (GIS) (CIK 0000040704) (GIS) — Oct 29, 2021
GENERAL MILLS INC (GIS) (CIK 0000040704)
Date: Oct. 29, 2021 · CIK: 0000040704 · Accession: 0000000000-21-013208
AI Filing Summary & Sentiment
File numbers found in text: 001-01185
Letter
United States securities and exchange commission logo October 29, 2021 Kofi A. Bruce Chief Financial Officer General Mills, Inc. Number One General Mills Boulevard Minneapolis, Minnesota 55426 Re:General Mills, Inc. Form 10-K for the Fiscal Year Ended May 30, 2021 Filed June 30, 2021 File No. 001-01185 Dear Mr. Bruce: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended May 30, 2021 Financial Statements Notes to Consolidated Financial Statements Note 9. Debt Long-Term Debt, page 69 1.We note that during the third quarter of fiscal 2021, you completed an exchange of $603.9 million of notes with interest rates between 4.15 and 5.4% for $605.2 million of 3% notes and a $201.4 million cash payment. Please tell us how you determined the exchange transaction qualified as a debt modification and not as a debt extinguishment under the guidance in ASC 470-50-40-6 through -12. In doing so, provide us with your cash flow present value calculations for the original and new notes under ASC 470-50-40-12. 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
FirstName LastNameKofi A. Bruce Comapany NameGeneral Mills, Inc. October 29, 2021 Page 2 FirstName LastName Kofi A. Bruce General Mills, Inc. October 29, 2021 Page 2 absence of action by the staff. You may contact Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
United States securities and exchange commission logo
October 29, 2021
Kofi A. Bruce
Chief Financial Officer
General Mills, Inc.
Number One General Mills Boulevard
Minneapolis, Minnesota 55426
Re:General Mills, Inc.
Form 10-K for the Fiscal Year Ended May 30, 2021
Filed June 30, 2021
File No. 001-01185
Dear Mr. Bruce:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended May 30, 2021
Financial Statements
Notes to Consolidated Financial Statements
Note 9. Debt
Long-Term Debt, page 69
1.We note that during the third quarter of fiscal 2021, you completed an exchange of $603.9
million of notes with interest rates between 4.15 and 5.4% for $605.2 million of 3% notes
and a $201.4 million cash payment. Please tell us how you determined the exchange
transaction qualified as a debt modification and not as a debt extinguishment under the
guidance in ASC 470-50-40-6 through -12. In doing so, provide us with your cash flow
present value calculations for the original and new notes under ASC 470-50-40-12.
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
FirstName LastNameKofi A. Bruce
Comapany NameGeneral Mills, Inc.
October 29, 2021 Page 2
FirstName LastName
Kofi A. Bruce
General Mills, Inc.
October 29, 2021
Page 2
absence of action by the staff.
You may contact Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing