SEC Comment Letter for V F (VFC) — Jan 15, 2009
V F CORP
Date: Jan. 15, 2009 · CIK: 0000103379 · Accession: 0000000000-09-002395
AI Filing Summary & Sentiment
File numbers found in text: 001-05256
Referenced dates: December 18, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-3561 DIVISION OF CORPORATION FINANCE Mail Stop 3561 January 15, 2009 Eric C. Wiseman President and Chief Executive Officer V. F. Corporation 105 Corporate Center Boulevard Greensboro, NC 27408
Re: V. F. Corporation Form 10-K for Fiscal Year Ended December 29, 2007 Filed February 26, 2008 Definitive Proxy Statement on Schedule 14A Filed March 17, 2008 File No. 001-05256
Dear Mr. Wiseman:
We have reviewed your filings and have the following comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your explanation. You should comply with the comment in all future filings, as applicable. Please conf irm in writing that you will do so and also explain to us how you intend to comply, within the time frame set forth below. Please understand that after our revi ew of your response, 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.
Form 10-K for Fiscal Year Ended December 29, 2007
Definitive Proxy Statement on Schedule 14A
Compensation Discussion and Analysis, page 15
Competitive Compensation Targets, page 17
1. We note your response to comment two fr om our letter dated December 18, 2008 that there are a large number of companies within the data pool, and no selection process. It appears from your disclosure and response that the company is aware of
Eric C. Wiseman V. F. Corporation January 15, 2009 Page 2
the identities of the companies within th e benchmark group when setting the target levels of compensation. Please confirm that in future filings you will identify the companies that comprise the benchmark group, as required by Item 402(b)(2)(xiv) of Regulation S-K.
* * * * *
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a le tter that keys your re sponse to our comment and provides any requested information. Detail ed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact John Archfi eld at (202) 551-3315 or Ryan Milne at (202) 551- 3688 if you have questions regarding comments on the financial statements and related matters. Please contact Louis Rambo at (202) 551-3289 or Pam Ho well at (202) 551-3357 with any other questions.
Sincerely,
John Reynolds
Assistant Director
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561
January 15, 2009
Eric C. Wiseman
President and Chief Executive Officer
V. F. Corporation
105 Corporate Center Boulevard
Greensboro, NC 27408
Re: V. F. Corporation
Form 10-K for Fiscal Year Ended December 29, 2007
Filed February 26, 2008
Definitive Proxy Statement on Schedule 14A
Filed March 17, 2008
File No. 001-05256
Dear Mr. Wiseman:
We have reviewed your filings and have the following comment. If you disagree,
we will consider your explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as deta iled as necessary in your explanation. You should comply
with the comment in all future filings, as applicable. Please conf irm in writing that you
will do so and also explain to us how you intend to comply, within the time frame set forth
below. Please understand that after our revi ew of your response, 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.
Form 10-K for Fiscal Year Ended December 29, 2007
Definitive Proxy Statement on Schedule 14A
Compensation Discussion and Analysis, page 15
Competitive Compensation Targets, page 17
1. We note your response to comment two fr om our letter dated December 18, 2008
that there are a large number of companies within the data pool, and no selection
process. It appears from your disclosure and response that the company is aware of
Eric C. Wiseman
V. F. Corporation
January 15, 2009 Page 2
the identities of the companies within th e benchmark group when setting the target
levels of compensation. Please confirm that in future filings you will identify the
companies that comprise the benchmark group, as required by Item 402(b)(2)(xiv)
of Regulation S-K.
* * * * *
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please furnish a le tter that keys your re sponse to our comment
and provides any requested information. Detail ed letters greatly facilitate our review.
Please understand that we may have additional comments after reviewing your response to
our comment.
You may contact John Archfi eld at (202) 551-3315 or Ryan Milne at (202) 551-
3688 if you have questions regarding comments on the financial statements and related
matters. Please contact Louis Rambo at (202) 551-3289 or Pam Ho well at (202) 551-3357
with any other questions.
Sincerely,
John Reynolds
Assistant Director