SEC Comment Letter for MCDONALDS CORP (MCD) (CIK 0000063908) (MCD) — Apr 18, 2007
MCDONALDS CORP (MCD) (CIK 0000063908)
Date: April 18, 2007 · CIK: 0000063908 · Accession: 0000000000-07-019092
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-05231
Referenced dates: April 12, 2007
Letter
April 18, 2007 Via U.S. Mail Mr. Matthew H. Paull Chief Financial Officer McDonald’s Corporation McDonald’s Plaza Oak Brook, Illinois 60523
RE: McDonald’s Corporation Form 10-K for the year ended December 31, 2006 Filed February 26, 2007 File No. 001-05231
Dear Mr. Paull:
We have reviewed your response letter dated April 12, 2007, and have the following comment. Unless otherwise indicated, we think you should revise your document in future filings in response to this comments. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please be as detailed as necessary in your explanat ion. In of our comment, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Please respond to confirm that such comment will be complied with, or, if the comment is deemed inappropriate, advise the sta ff of your reason. Your response should be submitted in electronic form, under the label “co rresp” with a copy to the staff. Please respond within ten (10) business days.
Mr. Matthew H. Paull McDonald’s Corporation April 18, 2007 Page 2 Annual Report on Form 10-K for the year ended December 31, 2006
Notes to Consolidated Financial Statements, page 34 Discontinued Operations, page 38
1. We note your response to our prior comme nt number 3 but do not concur with your conclusion that your disclosures pursuant to paragraph 47 of SFAS No.144 were adequate given the overall materiality of the gain recognized on the disposition of Chipotle in your financial statements. Accordingly, please revise the notes to your financial statements in future filings to include the following disclosures:
• Please disclose the facts and circumst ances leading to the disposal of Chipotle as required by paragraph 47a of SFAS No. 144. We do not believe providing these disclosures in MD&A or in previous SEC filings satisfies the financial statement disclosure requirements outlined in SFAS No. 144.
• Please disclose the revenue and pr e-tax profit and loss of Chipotle reflected in discontinued operations for all periods presented. Although these disclosures may not be material to your consolidated revenues and consolidated pre-tax profit they pres umably would be material to the segment results of the segment in which Chipotle was previously included.
• Please explain in your future segment disclosures where Chipotle was previously classified in your segm ent disclosures. Although you disclose in a footnote the assets of your discontinued operation, it is not apparent from the disclosures provided in your “Segment and Geographic Information” footnote where the Chi potle operations were previously classified. Please clarify this in your future segment disclosures.
You may contact Heather Clar k at (202) 551-3624 or me at (202) 551-3813 if you have questions.
Sincerely,
Linda Cvrkel
Branch Chief
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Mail Stop 3561 April 18, 2007 Via U.S. Mail Mr. Matthew H. Paull Chief Financial Officer McDonald’s Corporation McDonald’s Plaza Oak Brook, Illinois 60523 RE: McDonald’s Corporation Form 10-K for the year ended December 31, 2006 Filed February 26, 2007 File No. 001-05231 Dear Mr. Paull: We have reviewed your response letter dated April 12, 2007, and have the following comment. Unless otherwise indicated, we think you should revise your document in future filings in response to this comments. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please be as detailed as necessary in your explanat ion. In of our comment, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Please respond to confirm that such comment will be complied with, or, if the comment is deemed inappropriate, advise the sta ff of your reason. Your response should be submitted in electronic form, under the label “co rresp” with a copy to the staff. Please respond within ten (10) business days. Mr. Matthew H. Paull McDonald’s Corporation April 18, 2007 Page 2 Annual Report on Form 10-K for the year ended December 31, 2006 Notes to Consolidated Financial Statements, page 34 Discontinued Operations, page 38 1. We note your response to our prior comme nt number 3 but do not concur with your conclusion that your disclosures pursuant to paragraph 47 of SFAS No.144 were adequate given the overall materiality of the gain recognized on the disposition of Chipotle in your financial statements. Accordingly, please revise the notes to your financial statements in future filings to include the following disclosures: • Please disclose the facts and circumst ances leading to the disposal of Chipotle as required by paragraph 47a of SFAS No. 144. We do not believe providing these disclosures in MD&A or in previous SEC filings satisfies the financial statement disclosure requirements outlined in SFAS No. 144. • Please disclose the revenue and pr e-tax profit and loss of Chipotle reflected in discontinued operations for all periods presented. Although these disclosures may not be material to your consolidated revenues and consolidated pre-tax profit they pres umably would be material to the segment results of the segment in which Chipotle was previously included. • Please explain in your future segment disclosures where Chipotle was previously classified in your segm ent disclosures. Although you disclose in a footnote the assets of your discontinued operation, it is not apparent from the disclosures provided in your “Segment and Geographic Information” footnote where the Chi potle operations were previously classified. Please clarify this in your future segment disclosures. You may contact Heather Clar k at (202) 551-3624 or me at (202) 551-3813 if you have questions. Sincerely, Linda Cvrkel Branch Chief