SEC Comment Letter for AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717) (T) — Sep 4, 2015
AT&T INC. (T, TBB, TBC, T-PA, T-PC) (CIK 0000732717)
Date: Sept. 4, 2015 · CIK: 0000732717 · Accession: 0000000000-15-044475
AI Filing Summary & Sentiment
Letter
Mail Stop 3720 September 4, 2015 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, 2014 Filed February 20, 2015 Response Dated April 17, 2015 File No. 001 -8610
Dear Mr. Stephens :
We have reviewed your April 17, 2015 response to our comment letter and have the following comment s. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your r esponse.
After reviewing your response to these comments, we may have additional comments.
Note 12. Pension and Postretirement Benefits, page s 63 through 7 6
1. You disclosed on page 64 that the change in method used to estimate interest and servi ce costs resulted in a decrease in the service and interest components for pension cost in the fourth quarter of 201 4. Please disclose how the change impacted your financial statements in quantitative terms.
2. We noted that footnote 1 on page 67 disclosed the weighted average assumed discount rates to calculate pension cost in effect before and after the change. However, it appears that the assumed discount rates to calculate pension costs related to other postretirement
Mr. John J. Stephens AT&T Inc. September 4, 2015 Page 2
benefit (OPEB) plans were not affe cted. Please ensure the disclosure is clear about the discount rates assumed for OPEB plans , and ensure the disclosure of the assumed discount rates used to calculate pension costs reflect s the change, as appropriate.
3. Please expand t he critical acc ounting estimates discussion or the footnotes to describe the approach used to compute interest cost and service cost.
General
4. We note d from your April 17, 2015 response that you expect that certain of you non - GAAP measures will experience improvement of approximately $1 billion in 2015 by virtue of this change in estimate. We expect that you will provide transparent disclosure in your discussion of your non-GAA P measure s of the impact of the change to include quantification of the effect of the change in method .
You may contact Robert Shapiro, Staff Accountant , at (202) 551 -3273 or Robert S. Littlepage, Accounting Branch Chief, at (202) 551 -3361 if you have que stions regarding comments on the financial statements and related matters. Please contact Justin Kisner, Staff Attorney , at (202) 551 -3788, Kathleen Krebs, Special Counsel, at (202) 551 -3350 , or me at (202) 551-3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage, for
Show Raw Text
Mail Stop 3720 September 4, 2015 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, 2014 Filed February 20, 2015 Response Dated April 17, 2015 File No. 001 -8610 Dear Mr. Stephens : We have reviewed your April 17, 2015 response to our comment letter and have the following comment s. Please comply with the following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your r esponse. After reviewing your response to these comments, we may have additional comments. Note 12. Pension and Postretirement Benefits, page s 63 through 7 6 1. You disclosed on page 64 that the change in method used to estimate interest and servi ce costs resulted in a decrease in the service and interest components for pension cost in the fourth quarter of 201 4. Please disclose how the change impacted your financial statements in quantitative terms. 2. We noted that footnote 1 on page 67 disclosed the weighted average assumed discount rates to calculate pension cost in effect before and after the change. However, it appears that the assumed discount rates to calculate pension costs related to other postretirement Mr. John J. Stephens AT&T Inc. September 4, 2015 Page 2 benefit (OPEB) plans were not affe cted. Please ensure the disclosure is clear about the discount rates assumed for OPEB plans , and ensure the disclosure of the assumed discount rates used to calculate pension costs reflect s the change, as appropriate. 3. Please expand t he critical acc ounting estimates discussion or the footnotes to describe the approach used to compute interest cost and service cost. General 4. We note d from your April 17, 2015 response that you expect that certain of you non - GAAP measures will experience improvement of approximately $1 billion in 2015 by virtue of this change in estimate. We expect that you will provide transparent disclosure in your discussion of your non-GAA P measure s of the impact of the change to include quantification of the effect of the change in method . You may contact Robert Shapiro, Staff Accountant , at (202) 551 -3273 or Robert S. Littlepage, Accounting Branch Chief, at (202) 551 -3361 if you have que stions regarding comments on the financial statements and related matters. Please contact Justin Kisner, Staff Attorney , at (202) 551 -3788, Kathleen Krebs, Special Counsel, at (202) 551 -3350 , or me at (202) 551-3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spirgel Assistant Director AD Office 11 – Telecommunications