SEC Comment Letter for SERVICE CORP INTERNATIONAL (SCI) (CIK 0000089089) (SCI) — Dec 17, 2020
SERVICE CORP INTERNATIONAL (SCI) (CIK 0000089089)
Date: Dec. 17, 2020 · CIK: 0000089089 · Accession: 0000000000-20-012156
AI Filing Summary & Sentiment
File numbers found in text: 001-06402
Letter
United States securities and exchange commission logo December 17, 2020 Eric D. Tanzberger Senior Vice President and Chief Financial Officer Service Corporation International 1929 Allen Parkway Houston, Texas 77019 Re:Service Corporation International Form 10-K for the Fiscal Year Ended December 31, 2019 Filed on February 18, 2020 Response dated December 11, 2020 File No. 001-06402 Dear Mr. Tanzberger: We have reviewed your December 11, 2020 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our November 12, 2020 letter. Form 10-K for the Fiscal Year Ended December 31, 2019 Consolidated Financial Statements Consolidated Statement of Cash Flows, page 47 1.We have reviewed your response to comment 2. In arriving at your current accounting treatment for the debt securities in your trusts, please tell us how you considered the guidance in ASC 320-10-45-11, which permits the inclusion of cash flows related to trading securities in cash flows from operating activities in certain circumstances, but requires cash flows related to other types of debt securities to be classified as investing activities. Also, refer to ASC 320-10-35-1.
FirstName LastNameEric D. Tanzberger Comapany NameService Corporation International December 17, 2020 Page 2 FirstName LastName Eric D. Tanzberger Service Corporation International December 17, 2020 Page 2 You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker at (202) 551-3769, if you have any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
United States securities and exchange commission logo
December 17, 2020
Eric D. Tanzberger
Senior Vice President and Chief Financial Officer
Service Corporation International
1929 Allen Parkway
Houston, Texas 77019
Re:Service Corporation International
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed on February 18, 2020
Response dated December 11, 2020
File No. 001-06402
Dear Mr. Tanzberger:
We have reviewed your December 11, 2020 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
November 12, 2020 letter.
Form 10-K for the Fiscal Year Ended December 31, 2019
Consolidated Financial Statements
Consolidated Statement of Cash Flows, page 47
1.We have reviewed your response to comment 2. In arriving at your current accounting
treatment for the debt securities in your trusts, please tell us how you considered the
guidance in ASC 320-10-45-11, which permits the inclusion of cash flows related to
trading securities in cash flows from operating activities in certain circumstances, but
requires cash flows related to other types of debt securities to be classified as investing
activities. Also, refer to ASC 320-10-35-1.
FirstName LastNameEric D. Tanzberger
Comapany NameService Corporation International
December 17, 2020 Page 2
FirstName LastName
Eric D. Tanzberger
Service Corporation International
December 17, 2020
Page 2
You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker at (202) 551-3769, if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services