SEC Company Response from VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712) (VZ) — Sep 7, 2018
VERIZON COMMUNICATIONS INC (VZ) (CIK 0000732712)
Date: Sept. 7, 2018 · CIK: 0000732712 · Accession: 0000732712-18-000047
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08606
Referenced dates: August 28, 2018
Letter
Division of Corporation Finance Office of Telecommunications Verizon Communications Inc. Form 10-K for Fiscal Year Ended December 31, 2017 Filed February 23, 2018 File No. 001-08606
Dear Mr. French,
Verizon Communications Inc. (the “Company” or “we”) respectfully provides the following response to the comment contained in the letter (the “Comment Letter”) of the staff of the Division of Corporate Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated August 28, 2018, relating to the above-referenced filing.
To facilitate review, we have repeated the text of the Staff’s comment below and followed the comment with the Company’s response.
1.
Your presentation of the non-GAAP measure titled, “Consolidated EBITDA” excluding other income (expense) and equity in losses of unconsolidated businesses is inconsistent with question 103.01 of the updated Compliance, Disclosure and Interpretation guidance on non GAAP measures last updated on April 4, 2018. Please comply with this comment in future filings and in your next earnings release.
We respectfully advise the Staff that the Company will change how it calculates Consolidated EBITDA, and will adjust net income for only interest, taxes and depreciation and amortization expense, consistent with question 103.01 of the updated Compliance, Disclosure and Interpretation guidance on non-GAAP measures. The Company will also change how it calculates Consolidated Adjusted EBITDA by further adjusting Consolidated EBITDA for other
Verizon Communications Inc. File No. 001-08606
September 7, 2018 Page 2 of 2
income (expense) and equity in losses of unconsolidated businesses. These changes will be reflected in our future filings and earnings releases.
* * * * *
If the Staff has any questions regarding the Company’s response, you may contact me at (908) 559-5741.
Sincerely,
/s/ Anthony T. Skiadas
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CORRESP 1 filename1.htm Document Anthony T. Skiadas Senior Vice President and Controller Verizon Communications Inc. 1095 Avenue of the Americas New York, New York 10036 Phone 908 559-5741 tony.skiadas@verizon.com September 7, 2018 Mr. Terry French Accounting Branch Chief Division of Corporation Finance Office of Telecommunications U.S. Securities and Exchange Commission Mail Stop 3720 Washington, DC 20549 Re: Verizon Communications Inc. Form 10-K for Fiscal Year Ended December 31, 2017 Filed February 23, 2018 File No. 001-08606 Dear Mr. French, Verizon Communications Inc. (the “Company” or “we”) respectfully provides the following response to the comment contained in the letter (the “Comment Letter”) of the staff of the Division of Corporate Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated August 28, 2018, relating to the above-referenced filing. To facilitate review, we have repeated the text of the Staff’s comment below and followed the comment with the Company’s response. 1. Your presentation of the non-GAAP measure titled, “Consolidated EBITDA” excluding other income (expense) and equity in losses of unconsolidated businesses is inconsistent with question 103.01 of the updated Compliance, Disclosure and Interpretation guidance on non GAAP measures last updated on April 4, 2018. Please comply with this comment in future filings and in your next earnings release. We respectfully advise the Staff that the Company will change how it calculates Consolidated EBITDA, and will adjust net income for only interest, taxes and depreciation and amortization expense, consistent with question 103.01 of the updated Compliance, Disclosure and Interpretation guidance on non-GAAP measures. The Company will also change how it calculates Consolidated Adjusted EBITDA by further adjusting Consolidated EBITDA for other Verizon Communications Inc. File No. 001-08606 September 7, 2018 Page 2 of 2 income (expense) and equity in losses of unconsolidated businesses. These changes will be reflected in our future filings and earnings releases. * * * * * If the Staff has any questions regarding the Company’s response, you may contact me at (908) 559-5741. Sincerely, /s/ Anthony T. Skiadas Anthony T. Skiadas Senior Vice President and Controller cc: Mr. Matthew D. Ellis Mr. William L. Horton, Jr. Ms. Tracy Krause