SEC Comment Letter for KROGER CO (KR) (CIK 0000056873) (KR) — Oct 26, 2016
KROGER CO (KR) (CIK 0000056873)
Date: Oct. 26, 2016 · CIK: 0000056873 · Accession: 0000000000-16-098513
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 October 2 6, 2016 W. Rodney McMullen Chairman of the Board and Chief Executive Officer The Kroger Co. 1014 Vine Street Cincinnati, Ohio 45202
Re: The Kroger Co. Form 10-K for Fiscal Year Ended January 30, 2016 Response Dated October 4, 2016 File No. 1 -00303
Dear Mr. McMullen:
We have reviewed your October 4, 2016 response to our comment letter and have the following comment s. 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 note otherwise, our references to prior comments are to com ments in our September 7, 2016 letter .
Notes to Consolidat ed Financial Statements
Note 1. Accounting Policies
Segments, page 46
1. We have reviewed your response to comment 1 as well as the additiona l information regarding your operating divisions provided supplementally on October 19, 2016. You indicate in your correspondence that operating divisions are organized around geographical areas. However, it appears C -Stores represent a separate operatin g division and, according to the Kroger fact book, C -Stores span 18 states. Likewise, it appears Fred Meyer Jewelers represents a separate operating division from the Fred Meyer stores operating division ; yet Fred Meyer Jewelers tend to be housed within Fred Meyer store locations as well as shopping malls . It appears further elaboration in your proposed
W. Rodney McMullen The Kroger Co. October 2 6, 2016 Page 2
disclosures regarding the basis of organization of operating divisions/segments may be warranted. Please advise.
2. Please upload to EDGAR a copy of the tabular information regarding your operating divisions that you provided suppl ementally on October 19, 2016.
You may contact Robyn Manuel, Staff Accountant, at 202 -551-3823 or Donna Di Silvio, Staff Accountant, at 202 -551-3202 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3344 with any other questions.
Sincerely,
/s/ William H. Thompson
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Mail Stop 3561 October 2 6, 2016 W. Rodney McMullen Chairman of the Board and Chief Executive Officer The Kroger Co. 1014 Vine Street Cincinnati, Ohio 45202 Re: The Kroger Co. Form 10-K for Fiscal Year Ended January 30, 2016 Response Dated October 4, 2016 File No. 1 -00303 Dear Mr. McMullen: We have reviewed your October 4, 2016 response to our comment letter and have the following comment s. 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 note otherwise, our references to prior comments are to com ments in our September 7, 2016 letter . Notes to Consolidat ed Financial Statements Note 1. Accounting Policies Segments, page 46 1. We have reviewed your response to comment 1 as well as the additiona l information regarding your operating divisions provided supplementally on October 19, 2016. You indicate in your correspondence that operating divisions are organized around geographical areas. However, it appears C -Stores represent a separate operatin g division and, according to the Kroger fact book, C -Stores span 18 states. Likewise, it appears Fred Meyer Jewelers represents a separate operating division from the Fred Meyer stores operating division ; yet Fred Meyer Jewelers tend to be housed within Fred Meyer store locations as well as shopping malls . It appears further elaboration in your proposed W. Rodney McMullen The Kroger Co. October 2 6, 2016 Page 2 disclosures regarding the basis of organization of operating divisions/segments may be warranted. Please advise. 2. Please upload to EDGAR a copy of the tabular information regarding your operating divisions that you provided suppl ementally on October 19, 2016. You may contact Robyn Manuel, Staff Accountant, at 202 -551-3823 or Donna Di Silvio, Staff Accountant, at 202 -551-3202 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3344 with any other questions. Sincerely, /s/ William H. Thompson William H. Thompson Branch Chief Office of Consumer Products