SEC Comment Letter for Helmerich & Payne, Inc. (HP) (CIK 0000046765) (HP) — Mar 6, 2018
Helmerich & Payne, Inc. (HP) (CIK 0000046765)
Date: March 6, 2018 · CIK: 0000046765 · Accession: 0000000000-18-007053
AI Filing Summary & Sentiment
File numbers found in text: 001-04221
Letter
Mail Stop 4628 March 6, 2018 Via E -Mail Juan Pablo Tardio Chief Financial Officer Helmerich & Payne, Inc. 1437 S. Boulder Ave., Suite 1400 Tulsa, Oklahoma 74119
Re: Helmerich & Payne, Inc. Form 10-K for Fiscal Year Ended September 30, 2017 Filed November 22, 2017 File No. 001-04221
Dear Mr. Tardio :
We have limited our review of your filing to the financial statements and related disclosures 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.
Form 10 -K for Fiscal Year Ended September 30, 2017
Notes to Consolidated Financial Statements, page 54
Note 1 – Summary of Significant Accounting Policies, page 54
Valuation of Long -Lived Assets, page 56
1. You disclose on page 11 that you assessed you r idle drilling rigs as of September 30, 2017 and determined no additional impairment charges were necessary. Describe, in reasonable detail, the methodologies, estimates and assumptions underlying your assessment, including the extent to which assets wer e grouped and the basis for any such grouping. As part of your response, explain how your assessment took into consideration factors such as historical and future expectations for rig utilization levels and rig fleet status, the continued decline in your backlog and increase in the percentage of such backlog not reasonably expected to be filled . In this regard, we note that your investor
Juan Pablo Tardio Helmerich & Payne, Inc. March 6, 2018 Page 2
presentation dated October 4, 2017 indicated that 55% of available rigs were contracted as of October 4, 2017 and that in your International Land Operations, 22 of 38 rigs were idle as of October 4, 2017 . See FASB ASC paragraphs 360 -10-35-23 and 360 -10-35-29 through 360 -10-35-35.
We remind you that the company and its management are responsible for the accuracy and adequ acy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Jeannette Wong, Staff Accountant , at (202) 551 -2137 , or Kimberly Calder, Assistant Chief Accountant, at (202) 551 -3701 with any questions.
Sincerely,
/s/ Ethan Horowitz
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Mail Stop 4628 March 6, 2018 Via E -Mail Juan Pablo Tardio Chief Financial Officer Helmerich & Payne, Inc. 1437 S. Boulder Ave., Suite 1400 Tulsa, Oklahoma 74119 Re: Helmerich & Payne, Inc. Form 10-K for Fiscal Year Ended September 30, 2017 Filed November 22, 2017 File No. 001-04221 Dear Mr. Tardio : We have limited our review of your filing to the financial statements and related disclosures 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. Form 10 -K for Fiscal Year Ended September 30, 2017 Notes to Consolidated Financial Statements, page 54 Note 1 – Summary of Significant Accounting Policies, page 54 Valuation of Long -Lived Assets, page 56 1. You disclose on page 11 that you assessed you r idle drilling rigs as of September 30, 2017 and determined no additional impairment charges were necessary. Describe, in reasonable detail, the methodologies, estimates and assumptions underlying your assessment, including the extent to which assets wer e grouped and the basis for any such grouping. As part of your response, explain how your assessment took into consideration factors such as historical and future expectations for rig utilization levels and rig fleet status, the continued decline in your backlog and increase in the percentage of such backlog not reasonably expected to be filled . In this regard, we note that your investor Juan Pablo Tardio Helmerich & Payne, Inc. March 6, 2018 Page 2 presentation dated October 4, 2017 indicated that 55% of available rigs were contracted as of October 4, 2017 and that in your International Land Operations, 22 of 38 rigs were idle as of October 4, 2017 . See FASB ASC paragraphs 360 -10-35-23 and 360 -10-35-29 through 360 -10-35-35. We remind you that the company and its management are responsible for the accuracy and adequ acy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Jeannette Wong, Staff Accountant , at (202) 551 -2137 , or Kimberly Calder, Assistant Chief Accountant, at (202) 551 -3701 with any questions. Sincerely, /s/ Ethan Horowitz Ethan Horowitz Accounting Branch Chief Office of Natural Resources