SEC Comment Letter for VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712) (VZ) — Dec 29, 2015
VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712)
Date: Dec. 29, 2015 · CIK: 0000732712 · Accession: 0000000000-15-059768
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3720 December 29 , 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 November 10 , 2015 File No. 1-08606
Dear Mr. Skiadas :
We have reviewed you r November 10 , 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 apply 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. Please tell us how many operating segments the Company has identified subsequent to the 2015 reorganization. To the extent your identified operating segments have changed, please clarify how your identified operating segments reconcile to your two reportab le segments, including the significance of other operating segments not heretofore identified.
2. We note from your September 22, 2015 response the CODM receives financial and operational data with respect to each of Wireline’s customer groups – Mass Markets , Global Enterprise, and Global Wholesale – and that this financial and operational information includes revenues, Contribution Margin, and operational data. Please explain to us the following:
Mr. Anthony T. Skiadas Verizon Communications Inc. December 29 , 2015 Page 2
a. How often the CODM receives financial information for each of the three customer groups within Wireline. b. What the CODM uses Contribution Margin for during his review . c. Whether the SVP & President of Operations also receives revenue and Contribution Margin for each of the three customer groups within Wireline and, if so, what he uses this information for during his review . d. Whether any individuals are held accountable for operating results with respect to each of Wireline’s three customer groups.
3. Please confirm the level at which the CODM reviews budgets, and address whether he reviews budgets for each of Wireline’s customer groups. If not, tell us who is responsible for this review.
4. With respect to the organizational chart in Exhibit A of the November 10, 2015 response: a. Please tell us how the organizational chart ali gns to the three identified customer groups within Wireline. b. Please distinguish the roles and responsibilities of each individual within the organizational chart. c. Please clarify what the SVP & Group Presidents of Consumer Mass Business Sales & Service, Ver izon Enterprise Solutions, and Verizon Partner Solutions are held accountable for in their respective positions . To the extent they are held accountable for operating performance, please describe how they are held accountable .
5. Please tell us how you consi dered the requirements in ASC 250 -10-50-40. Specifically, please discuss how you evaluated your various product and service offerings within Mass Markets, Global Enterprise, and Global Wholesale. For example, we note from various earnings call transcripts that you discuss trends of FiOS and traditional networks separately.
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
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Mail Stop 3720 December 29 , 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 November 10 , 2015 File No. 1-08606 Dear Mr. Skiadas : We have reviewed you r November 10 , 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 apply 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. Please tell us how many operating segments the Company has identified subsequent to the 2015 reorganization. To the extent your identified operating segments have changed, please clarify how your identified operating segments reconcile to your two reportab le segments, including the significance of other operating segments not heretofore identified. 2. We note from your September 22, 2015 response the CODM receives financial and operational data with respect to each of Wireline’s customer groups – Mass Markets , Global Enterprise, and Global Wholesale – and that this financial and operational information includes revenues, Contribution Margin, and operational data. Please explain to us the following: Mr. Anthony T. Skiadas Verizon Communications Inc. December 29 , 2015 Page 2 a. How often the CODM receives financial information for each of the three customer groups within Wireline. b. What the CODM uses Contribution Margin for during his review . c. Whether the SVP & President of Operations also receives revenue and Contribution Margin for each of the three customer groups within Wireline and, if so, what he uses this information for during his review . d. Whether any individuals are held accountable for operating results with respect to each of Wireline’s three customer groups. 3. Please confirm the level at which the CODM reviews budgets, and address whether he reviews budgets for each of Wireline’s customer groups. If not, tell us who is responsible for this review. 4. With respect to the organizational chart in Exhibit A of the November 10, 2015 response: a. Please tell us how the organizational chart ali gns to the three identified customer groups within Wireline. b. Please distinguish the roles and responsibilities of each individual within the organizational chart. c. Please clarify what the SVP & Group Presidents of Consumer Mass Business Sales & Service, Ver izon Enterprise Solutions, and Verizon Partner Solutions are held accountable for in their respective positions . To the extent they are held accountable for operating performance, please describe how they are held accountable . 5. Please tell us how you consi dered the requirements in ASC 250 -10-50-40. Specifically, please discuss how you evaluated your various product and service offerings within Mass Markets, Global Enterprise, and Global Wholesale. For example, we note from various earnings call transcripts that you discuss trends of FiOS and traditional networks separately. 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