Correspondence 0000947871-24-000945 from CVS HEALTH Corp (CVS) (CIK 0000064803) (CVS)
CVS HEALTH Corp (CVS) (CIK 0000064803)
Date: Nov. 21, 2024 · CIK: 0000064803 · Accession: 0000947871-24-000945
AI Filing Summary & Sentiment
File numbers found in text: 001-01011
Referenced dates: November 19, 2024
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CORRESP
1
filename1.htm
By EDGAR
November 21, 2024
Valeria Franks and Angela Lumley
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, NE
Washington, D.C. 20549-0405
Re:
CVS Health Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-01011
Dear Mses. Franks and Lumley:
CVS Health Corporation (the “Company”)
is responding to the comment letter of the Staff of the U.S. Securities and Exchange Commission (the “Staff”) dated November
19, 2024 on the above referenced filing. For your convenience, we have reproduced the Staff’s comment in bold immediately preceding
the Company’s response.
Form 10-K for Fiscal Year Ended December 31, 2023
Consolidated Statements of Operations, page 109
1. Please remove dividends declared per share from your consolidated statements of operations and instead present this information
in your consolidated statements of stockholders' equity and/or footnotes. Similarly revise your Forms 10-Q and earnings releases. Refer
to ASC 505-10-S99-1, ASC 260-10-45-5 and SEC Release No. 33-10532.
We acknowledge the
Staff’s comment and respectfully submit that the Company will remove dividends declared per share from its consolidated statements
of operations in future filings of Forms 10-K, Forms 10-Q and earnings releases. The Company will instead present this information in
its consolidated statements of shareholders’ equity or the footnotes to the consolidated financial statements in future filings.
If you have any additional questions or
comments, please do not hesitate to contact me at thomas.cowhey@cvshealth.com.
Very truly yours,
/s/ Thomas F. Cowhey
Thomas F. Cowhey
Executive Vice President and Chief Financial Officer
cc: James D. Clark, Senior Vice President, Controller and Chief Accounting
Officer
Samrat S. Khichi, Executive Vice President, Chief Policy
Officer and General Counsel
Kristina V. Fink, Senior Vice President, Chief Governance Officer
and Corporate Secretary
Lona Nallengara, Allen Overy Shearman Sterling US
LLP