SEC Comment Letter 0000000000-22-012380 to WHIRLPOOL CORP /DE/ (WHR) (CIK 0000106640) (WHR)
WHIRLPOOL CORP /DE/ (WHR) (CIK 0000106640)
Date: Nov. 15, 2022 · CIK: 0000106640 · Accession: 0000000000-22-012380
AI Filing Summary & Sentiment
File numbers found in text: 001-03932
Letter
United States securities and exchange commission logo November 15, 2022 James W. Peters Chief Financial Officer Whirlpool Corporation 2000 North M-63 Benton Harbor, MI 49022-2692 Re:Whirlpool Corporation Form 10-K for Fiscal Year Ended December 31, 2021 Response Dated November 1, 2022 File No. 001-03932 Dear James W. Peters: We have reviewed your November 1, 2022 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 6, 2022 letter. Response Dated November 1, 2022 Risk Factors, page 13 1.Your response to comment one identifies a number of transition risks that are introduced by making changes to your supply chain, manufacturing processes, and product offerings. Please revise your disclosure to describe these transition risks or tell us how you determined that such disclosure is not required. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 2.Your response to comment three describes two weather-related claim events, but does not fully quantify the weather-related damages to your property or operations for the periods covered by the Form 10-K. Accordingly, we reissue this portion of our comment.
FirstName LastNameJames W. Peters Comapany NameWhirlpool Corporation November 15, 2022 Page 2 FirstName LastName James W. Peters Whirlpool Corporation November 15, 2022 Page 2 Please contact Patrick Fullem at (202) 551-8337 or Jennifer Angelini at (202) 551-3047 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Ava Harter
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United States securities and exchange commission logo
November 15, 2022
James W. Peters
Chief Financial Officer
Whirlpool Corporation
2000 North M-63
Benton Harbor, MI 49022-2692
Re:Whirlpool Corporation
Form 10-K for Fiscal Year Ended December 31, 2021
Response Dated November 1, 2022
File No. 001-03932
Dear James W. Peters:
We have reviewed your November 1, 2022 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
October 6, 2022 letter.
Response Dated November 1, 2022
Risk Factors, page 13
1.Your response to comment one identifies a number of transition risks that are introduced
by making changes to your supply chain, manufacturing processes, and product offerings.
Please revise your disclosure to describe these transition risks or tell us how you
determined that such disclosure is not required.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
28
2.Your response to comment three describes two weather-related claim events, but does not
fully quantify the weather-related damages to your property or operations for the periods
covered by the Form 10-K. Accordingly, we reissue this portion of our comment.
FirstName LastNameJames W. Peters
Comapany NameWhirlpool Corporation
November 15, 2022 Page 2
FirstName LastName
James W. Peters
Whirlpool Corporation
November 15, 2022
Page 2
Please contact Patrick Fullem at (202) 551-8337 or Jennifer Angelini at (202) 551-3047
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Ava Harter