SEC Comment Letter for HALLIBURTON CO (HAL) (CIK 0000045012) (HAL) — Jul 17, 2017
HALLIBURTON CO (HAL) (CIK 0000045012)
Date: July 17, 2017 · CIK: 0000045012 · Accession: 0000000000-17-024974
AI Filing Summary & Sentiment
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Letter
Mail Stop 4628 July 17 , 201 7 Via E -mail Christopher Weber Chief Financial Officer Halliburton Company 3000 North Sam Houston Parkway East Houston, Texas 77032
Re: Halliburton Company Form 10 -K for Fiscal Year Ended December 31, 201 6 Filed February 7, 201 7 Supplemental Response dated June 2 , 2017 File No. 1-03492
Dear Mr. Weber :
We have reviewed your June 2, 2017 response to our comment letter 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments. Unless we no te otherwise, our references to prior comments are to comments in our May 9, 2017 letter .
Form 10 -K for Fiscal Year Ended December 31, 2016
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
Critical Accounting Estimates, page 34
Allowance for Bad Debts, page 37
1. As it relates to your operations in Venezuela, based on historical experience and specific factors related to your primary customer, we note that you continue to believe outstanding receivables are collectable. Expand the revised disclosure provided in
Christopher Weber Halliburton Company July 17 , 201 7 Page 2
response to prior comment 4 regarding the process through which you analyze the collectability of your receivables in Venezuela to address the uncertainty associated with this critica l accounting policy and the sensitivity of your assumptions to change based on outcomes that management deems reasonably likely to occur. Explain in greater detail how you arrived at your estimate of collectability by addressing unique elements of your operations in Venezuela. Your revised disclosure should provide your assessment of factors that may differ from your historical experience such as the curtailment of your operations in Venezuela, the aging of your receivables, and amounts collected to date, along with other relevant considerations such as the loss recognized in connection with the financing agreement you entered into during the second quarter of 2016. Refer to Section V of Release 33 -8350.
You may contact Wei Lu, Staff Accountant, at (202) 551-3725 or me at (202) 551 -3311 with any other questions.
Sincerely,
/s/ Ethan Horowitz
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Mail Stop 4628 July 17 , 201 7 Via E -mail Christopher Weber Chief Financial Officer Halliburton Company 3000 North Sam Houston Parkway East Houston, Texas 77032 Re: Halliburton Company Form 10 -K for Fiscal Year Ended December 31, 201 6 Filed February 7, 201 7 Supplemental Response dated June 2 , 2017 File No. 1-03492 Dear Mr. Weber : We have reviewed your June 2, 2017 response to our comment letter 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we no te otherwise, our references to prior comments are to comments in our May 9, 2017 letter . Form 10 -K for Fiscal Year Ended December 31, 2016 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 19 Critical Accounting Estimates, page 34 Allowance for Bad Debts, page 37 1. As it relates to your operations in Venezuela, based on historical experience and specific factors related to your primary customer, we note that you continue to believe outstanding receivables are collectable. Expand the revised disclosure provided in Christopher Weber Halliburton Company July 17 , 201 7 Page 2 response to prior comment 4 regarding the process through which you analyze the collectability of your receivables in Venezuela to address the uncertainty associated with this critica l accounting policy and the sensitivity of your assumptions to change based on outcomes that management deems reasonably likely to occur. Explain in greater detail how you arrived at your estimate of collectability by addressing unique elements of your operations in Venezuela. Your revised disclosure should provide your assessment of factors that may differ from your historical experience such as the curtailment of your operations in Venezuela, the aging of your receivables, and amounts collected to date, along with other relevant considerations such as the loss recognized in connection with the financing agreement you entered into during the second quarter of 2016. Refer to Section V of Release 33 -8350. You may contact Wei Lu, Staff Accountant, at (202) 551-3725 or me at (202) 551 -3311 with any other questions. Sincerely, /s/ Ethan Horowitz Ethan Horowitz Branch Chief Office of Natural Resources