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UPLOAD Filing

O REILLY AUTOMOTIVE INC
Date: June 30, 2025 · CIK: 0000898173 · Accession: 0000000000-25-006882

Financial Reporting Regulatory Compliance Internal Controls

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Date
June 30, 2025
Author
Finance
Form
UPLOAD
Company
O REILLY AUTOMOTIVE INC

Letter

Re: O'Reilly Automotive, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Dear Jeremy Fletcher:

June 30, 2025

Jeremy Fletcher Executive Vice President and Chief Financial Officer O'Reilly Automotive, Inc. 233 South Patterson Avenue Springfield, Missouri 65802

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K for Fiscal Year Ended December 31, 2024 Consolidated Financial Statements Notes to Consolidated Financial Statements Note 1 - Summary of Signficant Accounting Policies Segment Reporting, page 51

1. Please tell us how your disclosure here and in note 3 comply with the requirement to disclose how the chief operating decision maker uses your reported measure of segment profit or loss in assessing segment performance and deciding how to allocate resources pursuant to ASC 280-10-50- 29.f. Refer to ASC 280-10-55-47.bb for guidance. Note 2 - Business Combination, page 57

2. Please tell us why it appears you did not provide disclosure pursuant to ASC 805-10- 50-2.h.1, 805-20-50-1.c, and 805-30-50-1.a. and b. regarding your acquisition of Vast Auto, and provide us with the relevant disclosure for each. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, June 30, 2025 Page 2

action or absence of action by the staff.

Please contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309 with any questions.

Sincerely,
Division of Corporation
Finance
Office of Trade &
Services

Show Raw Text
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<TEXT>
 June 30, 2025

Jeremy Fletcher
Executive Vice President and Chief Financial Officer
O'Reilly Automotive, Inc.
233 South Patterson Avenue
Springfield, Missouri 65802

 Re: O'Reilly Automotive, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
Dear Jeremy Fletcher:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 1 - Summary of Signficant Accounting Policies
Segment Reporting, page 51

1. Please tell us how your disclosure here and in note 3 comply with the
requirement to
 disclose how the chief operating decision maker uses your reported
measure of
 segment profit or loss in assessing segment performance and deciding how
to allocate
 resources pursuant to ASC 280-10-50- 29.f. Refer to ASC 280-10-55-47.bb
for
 guidance.
Note 2 - Business Combination, page 57

2. Please tell us why it appears you did not provide disclosure pursuant to
ASC 805-10-
 50-2.h.1, 805-20-50-1.c, and 805-30-50-1.a. and b. regarding your
acquisition of Vast
 Auto, and provide us with the relevant disclosure for each.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
 June 30, 2025
Page 2

action or absence of action by the staff.

 Please contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309
with
any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
</TEXT>
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