SEC Comment Letter for AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717) (T) — Jun 2, 2014
AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717)
Date: June 2, 2014 · CIK: 0000732717 · Accession: 0000000000-14-027825
AI Filing Summary & Sentiment
File numbers found in text: 001-08610
Letter
June 2 , 2014 Via E -mail Mr. John J. Stephens Senior Executive Vice President and Chief Financial Officer AT&T Inc. 208 S. Akard St. Dallas, TX 75202
Re: AT&T, Inc. Form 10-K for the Year Ended December 31, 201 3 Filed February 21, 201 4 File No. 001-08610
Dear Mr. Stephens:
We have reviewed your filing and have the following comment. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
Please respond to this letter wi thin ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 201 3
Notes to the Consolidated Financial Statements
Note 12. Pension and Postretirement Benefits, page 59 and Note 14. Stockholders Equity, Preferred Equity Interest, page 69
1. Please disclos e in Note 12 the restrictions on transferability of the preferred equity interest in AT&T Mobility II LLC (Mobility) as a plan asset of the pension plan trust or include a cross -reference t o Note 14 .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of
Mr. John J. Stephens AT&T Inc. June 2 , 2014 Page 2
1934 and all applicable Exchange Act rules 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.
In respond ing to our comments, 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 d o 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 Robert Shapiro , Staff Accountant, at (202) 551 -3273 or Ivette Leon , Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage, for
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June 2 , 2014 Via E -mail Mr. John J. Stephens Senior Executive Vice President and Chief Financial Officer AT&T Inc. 208 S. Akard St. Dallas, TX 75202 Re: AT&T, Inc. Form 10-K for the Year Ended December 31, 201 3 Filed February 21, 201 4 File No. 001-08610 Dear Mr. Stephens: We have reviewed your filing and have the following comment. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. Please respond to this letter wi thin ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 201 3 Notes to the Consolidated Financial Statements Note 12. Pension and Postretirement Benefits, page 59 and Note 14. Stockholders Equity, Preferred Equity Interest, page 69 1. Please disclos e in Note 12 the restrictions on transferability of the preferred equity interest in AT&T Mobility II LLC (Mobility) as a plan asset of the pension plan trust or include a cross -reference t o Note 14 . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of Mr. John J. Stephens AT&T Inc. June 2 , 2014 Page 2 1934 and all applicable Exchange Act rules 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. In respond ing to our comments, 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 d o 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 Robert Shapiro , Staff Accountant, at (202) 551 -3273 or Ivette Leon , Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spir gel Assistant Director