SEC Comment Letter for ATMOS ENERGY CORP (ATO) (CIK 0000731802) (ATO) — Feb 3, 2015
ATMOS ENERGY CORP (ATO) (CIK 0000731802)
Date: Feb. 3, 2015 · CIK: 0000731802 · Accession: 0000000000-15-006336
AI Filing Summary & Sentiment
Letter
February 3, 2015 Via E-mail Bret J. Eckert Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas , Texas 75240
Re: Atmos Energy Corporation Form 10-K for Fiscal Year Ended September 30, 2014 Filed November 6 , 2014 File No. 1-10042
Dear Mr . Eckert :
We have reviewed your filing 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our co mment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment , we may have addit ional comments.
Item 8. Financial Statements and Supplementary Data, page 46
Consolidated Statements of Income, page 49
1. Please quantify, on an absolute dollar basis, the revenue generated from sales of products, sales of services and other sales within your non -regulated businesses. Additionally, please tell us what c onsider ation you gave to separately disclosing revenues and cost of r evenues for products, services and other pursuant to Rules 5 - 03(b)(1) and (2) of Regulation S -X for your no n-regulated businesses .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rule s require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Bret J. Eckert Atmos Energy Corporation February 3, 2015 Page 2
In responding to our comment , please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Tony Watson, Acc ountant, at (202) 551 -3318 if you have questions regarding our comment . Please contact me at (202) 551 -3344 with any other questions.
Sincerely,
/s/ William H. Thompson
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February 3, 2015 Via E-mail Bret J. Eckert Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas , Texas 75240 Re: Atmos Energy Corporation Form 10-K for Fiscal Year Ended September 30, 2014 Filed November 6 , 2014 File No. 1-10042 Dear Mr . Eckert : We have reviewed your filing 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our co mment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment , we may have addit ional comments. Item 8. Financial Statements and Supplementary Data, page 46 Consolidated Statements of Income, page 49 1. Please quantify, on an absolute dollar basis, the revenue generated from sales of products, sales of services and other sales within your non -regulated businesses. Additionally, please tell us what c onsider ation you gave to separately disclosing revenues and cost of r evenues for products, services and other pursuant to Rules 5 - 03(b)(1) and (2) of Regulation S -X for your no n-regulated businesses . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rule s require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Bret J. Eckert Atmos Energy Corporation February 3, 2015 Page 2 In responding to our comment , please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Tony Watson, Acc ountant, at (202) 551 -3318 if you have questions regarding our comment . Please contact me at (202) 551 -3344 with any other questions. Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief