SEC Comment Letter 0000000000-23-001954 to VERIZON COMMUNICATIONS INC (VZ)
VERIZON COMMUNICATIONS INC
Date: Feb. 27, 2023 · CIK: 0000732712 · Accession: 0000000000-23-001954
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File numbers found in text: 001-08606
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United States securities and exchange commission logo
February 27, 2023
Matthew D. Ellis
Executive Vice President and Chief Financial Offider
Verizon Communications, Inc.
1095 Avenue of the Americas
New York, NY 10036
Re:Verizon Communications Inc.
Form 10-K for the Year Ended December 31, 2022
Filed February 10, 2023
Form 8-K filed January 24, 2023
File No. 001-08606
Dear Matthew D. Ellis:
We have limited our review of your filing to the financial statements and related
disclosures 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 comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 8-K filed January 24, 2023
Exhibit 99.1
Non-GAAP Reconciliations - Consolidated Verizon
Net Unsecured Debt and Net Unsecured Debt to Consolidated Adjusted EBITDA Ratio, page 16
1.We note your disclosure of the non-GAAP measure, Net Unsecured Debt to Consolidated
Adjusted EBITDA Ratio. In future filings, please show the ratio as calculated using the
most directly comparable GAAP financial measures. Refer to Item 10(e)(1)(i)(A) of
Regulation S-K and further guidance under footnote 27 to Exchange Act Release No.
47226.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameMatthew D. Ellis
Comapany NameVerizon Communications, Inc.
February 27, 2023 Page 2
FirstName LastName
Matthew D. Ellis
Verizon Communications, Inc.
February 27, 2023
Page 2
You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: William Horton