SEC Comment Letter for HONEYWELL INTERNATIONAL INC (HON) (CIK 0000773840) (HON) — Jul 5, 2012
HONEYWELL INTERNATIONAL INC (HON) (CIK 0000773840)
Date: July 5, 2012 · CIK: 0000773840 · Accession: 0000000000-12-035159
AI Filing Summary & Sentiment
Reasoning
Referenced dates: June 12, 2012
Letter
July 5, 201 2 Via E -mail Kathleen A. Winters Vice President and Controller Honeywell International Inc. 101 Columbia Road Morris Township, NJ 07962
Re: Honeywell International Inc. Form 10-K for Fiscal Y ear Ended December 31, 2011 Filed February 17 , 201 2 Response dated June 12, 2012 File No. 001 -08974
Dear Ms. Winters :
We have reviewed your response letter dated June 12, 2012 and have the following comment s. Our comment s ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information. If you do not believe our comment s apply to your facts and circumstances, plea se tell us why in your response.
After reviewing the information you provide in response to these comment s, we may have additional comments.
Cybersecurity incidents could disrupt business operations, page 12
1. In response to our prior com ment 1, you state that the types of cybersecurity threats and incidents that you have experienced fall within the range of threats identified in your cybersecurity risk factor on page 12 of your Form 10 -K. Beginning with your next Form 10 - Q, please expand your risk factor to simply state this fact.
Management’s Discussion and Analysis, page 23
Critical Accounting Policies, page 47
Sales Recognition on Long -Term Contracts, page 52
2. We note your response to our prior comment 2 relating to the impacts of changes in estimates on your results. Should aggregate net adjustments become material to segment profit or
Kathleen A. Winters Honeywell International Inc. July 5, 2012 Page 2
consolidated operating income in the future, please separately quantify gross favorable and gross unfavorable changes in estimates material to eith er consolidated or segment results, accompanied by an appropriate level of analysis. We believe disclosure on this basis complies with the requirements of ASC 250 -10-50-4, ASC 605 -35-25-86, and ASC 605 -35- 50-9 and believe such disclosure will give investo rs more insight to the estimation process associated with your contracts, as discussed in “Critical Accounting Policies,” and the impacts on your results.
You may contact Patrick Kuhn at (202) 551 -3308 or me at (202) 551 -3380 with any questions regardin g comments on the financial statements and related matte rs. Please contact Nolan McWilliams at (202) 551 -3217 or Lauren Nguyen at (202) 551 -3642 with any other questions.
Sincerely,
/s/ Lyn Shenk
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July 5, 201 2 Via E -mail Kathleen A. Winters Vice President and Controller Honeywell International Inc. 101 Columbia Road Morris Township, NJ 07962 Re: Honeywell International Inc. Form 10-K for Fiscal Y ear Ended December 31, 2011 Filed February 17 , 201 2 Response dated June 12, 2012 File No. 001 -08974 Dear Ms. Winters : We have reviewed your response letter dated June 12, 2012 and have the following comment s. Our comment s ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information. If you do not believe our comment s apply to your facts and circumstances, plea se tell us why in your response. After reviewing the information you provide in response to these comment s, we may have additional comments. Cybersecurity incidents could disrupt business operations, page 12 1. In response to our prior com ment 1, you state that the types of cybersecurity threats and incidents that you have experienced fall within the range of threats identified in your cybersecurity risk factor on page 12 of your Form 10 -K. Beginning with your next Form 10 - Q, please expand your risk factor to simply state this fact. Management’s Discussion and Analysis, page 23 Critical Accounting Policies, page 47 Sales Recognition on Long -Term Contracts, page 52 2. We note your response to our prior comment 2 relating to the impacts of changes in estimates on your results. Should aggregate net adjustments become material to segment profit or Kathleen A. Winters Honeywell International Inc. July 5, 2012 Page 2 consolidated operating income in the future, please separately quantify gross favorable and gross unfavorable changes in estimates material to eith er consolidated or segment results, accompanied by an appropriate level of analysis. We believe disclosure on this basis complies with the requirements of ASC 250 -10-50-4, ASC 605 -35-25-86, and ASC 605 -35- 50-9 and believe such disclosure will give investo rs more insight to the estimation process associated with your contracts, as discussed in “Critical Accounting Policies,” and the impacts on your results. You may contact Patrick Kuhn at (202) 551 -3308 or me at (202) 551 -3380 with any questions regardin g comments on the financial statements and related matte rs. Please contact Nolan McWilliams at (202) 551 -3217 or Lauren Nguyen at (202) 551 -3642 with any other questions. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief