SEC Company Response from HASBRO, INC. (HAS) (CIK 0000046080) (HAS) — Sep 20, 2018
HASBRO, INC. (HAS) (CIK 0000046080)
Date: Sept. 20, 2018 · CIK: 0000046080 · Accession: 0000046080-18-000126
AI Filing Summary & Sentiment
File numbers found in text: 001-06682
Referenced dates: September 6, 2018
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CORRESP
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September 20, 2018
Division of Corporation Finance
Office of Transportation and Leisure
United States
Securities and Exchange Commission
Washington, D.C. 20549
Attn: Heather Clark
Claire Erlanger
Re: Hasbro, Inc.
Form 10-K for the Fiscal Year Ended December 31,
2017
Form 10-Q for the Fiscal Quarter Ended July 1, 2018
File No. 001-06682
Dear Ms. Clark and Ms. Erlanger:
This letter is submitted on behalf of Hasbro, Inc. (the “Company”),
in response to the comments that you have provided on behalf of the staff of
the Division of Corporation Finance (the “Staff”) of the Securities and
Exchange Commission (the “SEC”) in your letter dated September 6, 2018.
For your convenience, we have set forth the original
comments from your letter in bold and italicized typeface to which we are
responding.
Form 10-Q for the Fiscal Quarter Ended July 1, 2018
Financial Statements
Condensed Notes to Consolidated Financial Statements
(9) Pension and Postretirement Benefits, page 1
1. We note your response to our prior comment 1 and the
disclosure in the Form 10-Q for the quarter ended July 1, 2018 which indicates
that upon settlement of the pension liability, you will reclassify the related
pension losses currently recorded to accumulated other comprehensive loss, to
the consolidated statements of operations. Please tell us, and revise your
disclosure to indicate the estimated amount of net unrealized losses that you
expect to recognize upon settlement. You may preface the amount by indicating
that the actual amount may differ due to changes in interest rates, pension plan
asset returns and other factors.
Response
The Company notes the SEC’s additional comments on the Company’s
planned termination of its U.S. defined benefit pension plan. The Company will revise its disclosure in future
filings to indicate the unrecognized losses remaining in accumulated other
comprehensive loss. Please refer to the revised disclosure below for the
Company’s intended disclosure in its future filings.
“In connection with the decision to terminate the Plan, the
Company remeasured the projected benefit obligation based on the expected Plan
termination costs. This remeasurement utilized a discount rate of 3.2% compared
to the discount rate of 3.7% utilized in the December 31, 2017 measurement and
resulted in an increase in the projected
benefit obligation of $35,192 with offsetting amounts recorded to accumulated
other comprehensive losses and deferred taxes. Upon
settlement of the pension liability, the Company will reclassify the related
pension losses currently recorded to accumulated other comprehensive loss, to
the consolidated statements of operations. As of July 1, 2018, the Company
had unrecognized losses related to the Plan of $145.5 million. The final loss
to be recognized upon termination of the Plan will be based on the Plan’s
unrecognized losses in accumulated other comprehensive loss, adjusted for
year-end remeasurement, as well as the total required payout to plan
participants which will be determined based on employee elections and market
conditions present at the time of termination.”
If you have
any questions or desire further information regarding the Company’s responses,
please contact me at (401) 727-5500.
Sincerely,
/s/ Deborah Thomas
Deborah
Thomas
Executive
Vice President and Chief Financial Officer
(Duly
Authorized Officer and Principal Financial Officer)