SEC Comment Letter for WPP plc (WPP, WPPGF) (CIK 0000806968) (WPP) — Sep 27, 2017
WPP plc (WPP, WPPGF) (CIK 0000806968)
Date: Sept. 27, 2017 · CIK: 0000806968 · Accession: 0000000000-17-034378
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-16350
Letter
Mail Stop 3720 September 27, 2017 Paul W.G. Richardson Group Chief Financial Officer WPP plc 27 Farm Street London, United Kingdom, W1J 5RJ
Re: WPP plc Form 20-F for Fiscal Year Ended December 31, 201 6 Filed April 28, 2017 File No. 000-16350
Dear Mr. Richardson :
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 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 response.
After reviewing your response to these comments, we may have additional comments.
Consolidated Income Statement, page F -8
1. We note your presentation of “net sales” and, as disclosed on page 2, that you previously referred to this subtotal as “gross profit.” It is not clear why you changed the label from “gross profit” to “net sales;” what this subtotal is intended to represent; and why i t is relevant to an understanding of the entity's financial performance. Please explain. Refer to IAS 1.85 and IAS 1.85A.
2. Please tell us your policy for determining functionally which costs are classified as “operating” or “direct.” We note that “oper ating” includes costs associated with your staff and establishment. Please tell us why these costs are not attributable to direct costs
Paul W.G. Richardson WPP plc September 27, 2017 Page 2
and further why you believe that “net sales” is a complete depiction that includes all information necessary for a user to understand the subtotal.
3. Further, please tell us what consideration you gave to allocating costs to functions other than direct or operating costs. Refer to IAS 1.103.
4. Clarify for us whether the Revenue line item includes the gross amount billed when you act as principal and it only includes the net amount retained when you act as agent.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, actio n or absence of action by the staff.
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Carlos Pacho
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Mail Stop 3720 September 27, 2017 Paul W.G. Richardson Group Chief Financial Officer WPP plc 27 Farm Street London, United Kingdom, W1J 5RJ Re: WPP plc Form 20-F for Fiscal Year Ended December 31, 201 6 Filed April 28, 2017 File No. 000-16350 Dear Mr. Richardson : 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 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 response. After reviewing your response to these comments, we may have additional comments. Consolidated Income Statement, page F -8 1. We note your presentation of “net sales” and, as disclosed on page 2, that you previously referred to this subtotal as “gross profit.” It is not clear why you changed the label from “gross profit” to “net sales;” what this subtotal is intended to represent; and why i t is relevant to an understanding of the entity's financial performance. Please explain. Refer to IAS 1.85 and IAS 1.85A. 2. Please tell us your policy for determining functionally which costs are classified as “operating” or “direct.” We note that “oper ating” includes costs associated with your staff and establishment. Please tell us why these costs are not attributable to direct costs Paul W.G. Richardson WPP plc September 27, 2017 Page 2 and further why you believe that “net sales” is a complete depiction that includes all information necessary for a user to understand the subtotal. 3. Further, please tell us what consideration you gave to allocating costs to functions other than direct or operating costs. Refer to IAS 1.103. 4. Clarify for us whether the Revenue line item includes the gross amount billed when you act as principal and it only includes the net amount retained when you act as agent. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, actio n or absence of action by the staff. You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Carlos Pacho Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications