SEC Comment Letter for PLDT Inc. (PHI, PHTCF) (CIK 0000078150) (PHI) — Oct 8, 2015
PLDT Inc. (PHI, PHTCF) (CIK 0000078150)
Date: Oct. 8, 2015 · CIK: 0000078150 · Accession: 0000000000-15-049110
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3720 October 8, 2015 Anabelle L. Chua Chief Financial Officer Philippine Long Distance Telephone Company Ramon Cojuangco Building Makati Avenue Makati City, Philippines
Re: Philippine Long Distance Telephone Company Form 20-F for Fiscal Year Ended December 31, 2014 Response Dated September 7, 2015 File No. 1-03006
Dear Ms. Chua:
We have reviewed your September 7, 2015 response to our comment letter and have the following c omment. In our comment , we ask you to provide us with information so we may better understand your disclosure.
Please respond to th is comment within ten business days by providing the r equested information or advise us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to th is comment, we may have add itional comments.
10. Investments in Associates, Joint Ventures and Deposits, page 324
Investments in Associates, page 325
We note your response to prior comment one. In your response you state that; “There were common directors and officers between PLDT and its subsidiaries, on the one hand, and Cignal TV and Satventures, on the other hand.. Certain managerial personnel and employees were seconded from PLDT and its subsidiaries to Cignal TV and Saltventures.” Given the relationships between PLDT and Cignal TV and Satventures, tell us your consideration of paragraphs B18 -B25 and B36 -B38 of IFRS 10 in
Anabelle L. Chua Philippine Long Distance Company October 8 , 2015 Page 2
determining whether Cignal TV, and Saltventures operations are dependent on PLDT and whether they provide evidence of existing power over Cigna l TV and Saltventures.
You may contact Inessa Kessman at 202-551-3371 or Terry French at 202-551-3828 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Terry French for
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Mail Stop 3720 October 8, 2015 Anabelle L. Chua Chief Financial Officer Philippine Long Distance Telephone Company Ramon Cojuangco Building Makati Avenue Makati City, Philippines Re: Philippine Long Distance Telephone Company Form 20-F for Fiscal Year Ended December 31, 2014 Response Dated September 7, 2015 File No. 1-03006 Dear Ms. Chua: We have reviewed your September 7, 2015 response to our comment letter and have the following c omment. In our comment , we ask you to provide us with information so we may better understand your disclosure. Please respond to th is comment within ten business days by providing the r equested information or advise us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response to th is comment, we may have add itional comments. 10. Investments in Associates, Joint Ventures and Deposits, page 324 Investments in Associates, page 325 We note your response to prior comment one. In your response you state that; “There were common directors and officers between PLDT and its subsidiaries, on the one hand, and Cignal TV and Satventures, on the other hand.. Certain managerial personnel and employees were seconded from PLDT and its subsidiaries to Cignal TV and Saltventures.” Given the relationships between PLDT and Cignal TV and Satventures, tell us your consideration of paragraphs B18 -B25 and B36 -B38 of IFRS 10 in Anabelle L. Chua Philippine Long Distance Company October 8 , 2015 Page 2 determining whether Cignal TV, and Saltventures operations are dependent on PLDT and whether they provide evidence of existing power over Cigna l TV and Saltventures. You may contact Inessa Kessman at 202-551-3371 or Terry French at 202-551-3828 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Terry French for Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications