SEC Comment Letter for SYSCO CORP (SYY) (CIK 0000096021) (SYY) — Apr 12, 2016
SYSCO CORP (SYY) (CIK 0000096021)
Date: April 12, 2016 · CIK: 0000096021 · Accession: 0000000000-16-071822
AI Filing Summary & Sentiment
File numbers found in text: 001-06544
Letter
Mail Stop 3561 April 1 2, 2016 William J. Delaney President and Chief Executive Officer Sysco Corp oration 1390 Enclave Parkway Houston, TX 77077
Re: Sysco Corp oration Form 10-K for the fiscal year ended June 27, 2015 Filed August 25, 2015 Response Dated March 31, 2016 File No. 001-06544
Dear Mr. Delaney :
We have reviewed your March 31, 2016 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not b elieve 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 March 16 , 2016 letter .
Item 8. Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
Note 9. Derivative Financial Instruments, page 65
1. Your response to question 5 indicates that the company is not amortizing AOCI to earnings based on the October 2014 debt but as the hedged fixed interest pay ments impact earnings. However you stated on page 66 of the 10 -K, as well as on page 9 of your Fo rm 10 -Q for the quarter ended December 26, 2015, that “ cumulative losses recorded in Accumulated other comprehensive (loss) income related to these swaps will continue to be amortized through interest expense over the term of the originally issued
William J. Delaney Sysco Corporation April 1 2, 2016 Page 2
debt as the amount hedged is anticipated to remain within our capital structure. ” [Emphasis added.] For the AOCI related to the swaps terminated in September 2014, please explain to us what you meant by “the term of the originally issued debt” and why this discl osure is consistent with your response to question 5.
You may contact Lisa Sellars, Staff Accountant, at (202) 551 -3348 or me at (202) 551 - 3849 if you have questions regarding the comment on the financial statements and re lated matters. Please contact Daniel Porco, Staff Attorney, at (202) 551 -3477 or Lilyanna Peyser, Special Counsel, at (202) 551 -3222 with any other questions.
Sincerely,
/s/ James Allegretto
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Mail Stop 3561 April 1 2, 2016 William J. Delaney President and Chief Executive Officer Sysco Corp oration 1390 Enclave Parkway Houston, TX 77077 Re: Sysco Corp oration Form 10-K for the fiscal year ended June 27, 2015 Filed August 25, 2015 Response Dated March 31, 2016 File No. 001-06544 Dear Mr. Delaney : We have reviewed your March 31, 2016 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not b elieve 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 March 16 , 2016 letter . Item 8. Financial Statements and Supplementary Data Notes to Consolidated Financial Statements Note 9. Derivative Financial Instruments, page 65 1. Your response to question 5 indicates that the company is not amortizing AOCI to earnings based on the October 2014 debt but as the hedged fixed interest pay ments impact earnings. However you stated on page 66 of the 10 -K, as well as on page 9 of your Fo rm 10 -Q for the quarter ended December 26, 2015, that “ cumulative losses recorded in Accumulated other comprehensive (loss) income related to these swaps will continue to be amortized through interest expense over the term of the originally issued William J. Delaney Sysco Corporation April 1 2, 2016 Page 2 debt as the amount hedged is anticipated to remain within our capital structure. ” [Emphasis added.] For the AOCI related to the swaps terminated in September 2014, please explain to us what you meant by “the term of the originally issued debt” and why this discl osure is consistent with your response to question 5. You may contact Lisa Sellars, Staff Accountant, at (202) 551 -3348 or me at (202) 551 - 3849 if you have questions regarding the comment on the financial statements and re lated matters. Please contact Daniel Porco, Staff Attorney, at (202) 551 -3477 or Lilyanna Peyser, Special Counsel, at (202) 551 -3222 with any other questions. Sincerely, /s/ James Allegretto James Allegretto Senior Assistant Chief Accountant Office of Consumer Products