SEC Comment Letter for VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712) (VZ) — Oct 13, 2015
VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712)
Date: Oct. 13, 2015 · CIK: 0000732712 · Accession: 0000000000-15-049446
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3720 October 13 , 2015 Mr. Anthony T. Skiadas Senior Vice President and Controller Verizon Communications Inc. 1095 Avenue of the Americas New York, New York 10036
Re: Verizon Communications Inc. Form 10 -K for Fiscal Year Ended December 31, 2014 Filed February 23, 2015 Response dated September 22, 2015 File No. 1-08606
Dear Mr. Skiadas :
We have reviewed you r September 22, 2015 response to our comment letter and have the following comment s. In our comment s, we ask you to provide us with information so we may better understand your disclosure.
Please respond to these comment s within ten business days by providing the requested information or advise us as soo n as possible when you will respond. If you do not believe our comment s applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to th ese comment s, we may have additional comments.
1. We no te on page 8 of your r esponse that the Presidents of Enterprise Solutions and Consumer and Mass Business Markets did not regularly review operating performance with the CODM. Please tell us the number of occasions that the individuals did meet with the CO DM. To the extent there were meetings, tell us the purpose of the meetings and whether the EVP of Wireless participated in those meetings.
2. We note on page 8 that the CODM reviews and makes revisions to budgets prepared by the segment managers. Please de scribe to us this process in more detail. Include in your response the level of the organization that the CODM reviews and revises budgets.
Mr. Anthony T. Skiadas Verizon Communi cations Inc. October 13 , 2015 Page 2
3. We note from your response that the reorganization in 2015 did not impact the determination of your CODM or how th e CODM manages your business and makes decisions. As it relates to your reorganization, please tell us the following:
the reasons for the reorganization; the nature and type of decisions that the EVP and President of Operations makes; the nature and type of decisions that the CEO makes; which individuals report directly to the EVP and President of Operations; and an explanation of any other changes from 2014 resulting from the reorganization that impacted the organizational reporting structure, decision - making process, or budgeting.
You may contact Sharon Virga, Staff Accountant , at (202) 551-3385 or Terry French, Accountant Branch Chief, at (202) 551 -3828 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Terry French for
Show Raw Text
Mail Stop 3720 October 13 , 2015 Mr. Anthony T. Skiadas Senior Vice President and Controller Verizon Communications Inc. 1095 Avenue of the Americas New York, New York 10036 Re: Verizon Communications Inc. Form 10 -K for Fiscal Year Ended December 31, 2014 Filed February 23, 2015 Response dated September 22, 2015 File No. 1-08606 Dear Mr. Skiadas : We have reviewed you r September 22, 2015 response to our comment letter and have the following comment s. In our comment s, we ask you to provide us with information so we may better understand your disclosure. Please respond to these comment s within ten business days by providing the requested information or advise us as soo n as possible when you will respond. If you do not believe our comment s applies to your facts and circumstances, please tell us why in your response. After reviewing your response to th ese comment s, we may have additional comments. 1. We no te on page 8 of your r esponse that the Presidents of Enterprise Solutions and Consumer and Mass Business Markets did not regularly review operating performance with the CODM. Please tell us the number of occasions that the individuals did meet with the CO DM. To the extent there were meetings, tell us the purpose of the meetings and whether the EVP of Wireless participated in those meetings. 2. We note on page 8 that the CODM reviews and makes revisions to budgets prepared by the segment managers. Please de scribe to us this process in more detail. Include in your response the level of the organization that the CODM reviews and revises budgets. Mr. Anthony T. Skiadas Verizon Communi cations Inc. October 13 , 2015 Page 2 3. We note from your response that the reorganization in 2015 did not impact the determination of your CODM or how th e CODM manages your business and makes decisions. As it relates to your reorganization, please tell us the following: the reasons for the reorganization; the nature and type of decisions that the EVP and President of Operations makes; the nature and type of decisions that the CEO makes; which individuals report directly to the EVP and President of Operations; and an explanation of any other changes from 2014 resulting from the reorganization that impacted the organizational reporting structure, decision - making process, or budgeting. You may contact Sharon Virga, Staff Accountant , at (202) 551-3385 or Terry French, Accountant Branch Chief, at (202) 551 -3828 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Terry French for Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications