SEC Comment Letter for RPC INC (RES) (CIK 0000742278) (RES) — Dec 15, 2016
RPC INC (RES) (CIK 0000742278)
Date: Dec. 15, 2016 · CIK: 0000742278 · Accession: 0000000000-16-105087
AI Filing Summary & Sentiment
Letter
Mail Stop 4628 December 1 5, 201 6 Via E -mail Ben M. Palmer Chief Financial Officer RPC, Inc. 2801 Buford Highway, Suite 520 Atlanta, Georgia 30329
Re: RPC, Inc. Form 10 -K for Fiscal Year Ended December 31, 201 5 Filed February 2 9, 201 6 Form 8 -K filed October 26 , 2016 File No. 1 -08726
Dear Mr. Palmer :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 busine ss days by providing the requested information or advis e 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 response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2015
Financial Statements and Supplementary Data, page 33
Notes to Consolidated Financial Statements, page 38
Note 12: Business Segment Information, page 57
1. We note that your service lines have been aggregated into two reportable segments. Describe your application of FASB ASC 280 -10-50-11 in evaluating the similarities between the financial performance of and approach to managing the service lines within each r eportable segment along with the economic and business conditions impacting their business activity levels. As part of your response, tell us whether each of the service
Ben M. Palmer RPC, Inc. December 1 5, 2016 Page 2
lines identified in your Form 10 -K is deemed to be an operating segment pursuant to FASB ASC 280 -10-50-1 and describe your basis of organization.
Form 8 -K filed October 26, 2016
2. The non -GAAP financial measures provided in your Form 8 -K include a presentation of EBITDA per share. Please revise as the presentation of EBITDA per share is n ot consistent with the guidance in question 103.02 of the Compliance and Disclosure Interpretation regarding Non -GAAP Financial Measures.
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.
You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or me at (202) 551 -3311 with any questions.
Sincerely,
/s/ Ethan Horowitz
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Mail Stop 4628 December 1 5, 201 6 Via E -mail Ben M. Palmer Chief Financial Officer RPC, Inc. 2801 Buford Highway, Suite 520 Atlanta, Georgia 30329 Re: RPC, Inc. Form 10 -K for Fiscal Year Ended December 31, 201 5 Filed February 2 9, 201 6 Form 8 -K filed October 26 , 2016 File No. 1 -08726 Dear Mr. Palmer : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 busine ss days by providing the requested information or advis e 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 response. After reviewing your response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2015 Financial Statements and Supplementary Data, page 33 Notes to Consolidated Financial Statements, page 38 Note 12: Business Segment Information, page 57 1. We note that your service lines have been aggregated into two reportable segments. Describe your application of FASB ASC 280 -10-50-11 in evaluating the similarities between the financial performance of and approach to managing the service lines within each r eportable segment along with the economic and business conditions impacting their business activity levels. As part of your response, tell us whether each of the service Ben M. Palmer RPC, Inc. December 1 5, 2016 Page 2 lines identified in your Form 10 -K is deemed to be an operating segment pursuant to FASB ASC 280 -10-50-1 and describe your basis of organization. Form 8 -K filed October 26, 2016 2. The non -GAAP financial measures provided in your Form 8 -K include a presentation of EBITDA per share. Please revise as the presentation of EBITDA per share is n ot consistent with the guidance in question 103.02 of the Compliance and Disclosure Interpretation regarding Non -GAAP Financial Measures. 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. You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or me at (202) 551 -3311 with any questions. Sincerely, /s/ Ethan Horowitz Ethan Horowitz Accounting Branch Chief Office of Natural Resources