SEC Comment Letter 0000000000-26-002241 to COSTCO WHOLESALE CORP /NEW (COST)
COSTCO WHOLESALE CORP /NEW
Date: March 4, 2026 · CIK: 0000909832 · Accession: 0000000000-26-002241
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-20355
Letter
March 4, 2026 Gary Millerchip Executive Vice President and Chief Financial Officer Costco Wholesale Corporation 999 Lake Drive Issaquah, WA 98027 Re:Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 File No. 000-20355 Dear Gary Millerchip: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). 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 August 31, 2025 Management's Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources Cash Flows from Operating Activities, page 29 1.Please provide a period to period comparative analysis and discussion of changes in cash flows from operating activities, including changes in working capital components, in your annual and interim period reports. In doing so, explain the underlying business reasons and implications of material changes between periods to provide investors with an understanding of variability and potential trends in cash flows. Ensure your discussion and analysis is not merely a recitation of changes evident from the consolidated statements of cash flows. Refer to Item 303(a) and (b) of Regulation S-K and SEC Release No. 33-8350.
March 4, 2026 Page 2 Notes to Consolidated Financial Statements Note 11 - Segment Reporting, page 62 2.You disclose the CODM utilizes operating income in evaluating performance and allocating resources but not how the measure is used for these purposes. Refer to ASC 280-10-50-29(f) and ASC 280-10-55-47(bb). Please revise as appropriate. 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, action or absence of action by the staff. Please contact Robert Shapiro at 202-551-3273 or Doug Jones at 202-551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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March 4, 2026
Gary Millerchip
Executive Vice President and Chief Financial Officer
Costco Wholesale Corporation
999 Lake Drive
Issaquah, WA 98027
Re:Costco Wholesale Corporation
Form 10-K for Fiscal Year Ended August 31, 2025
File No. 000-20355
Dear Gary Millerchip:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
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 August 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Cash Flows from Operating Activities, page 29
1.Please provide a period to period comparative analysis and discussion of changes in cash
flows from operating activities, including changes in working capital components, in
your annual and interim period reports. In doing so, explain the underlying business
reasons and implications of material changes between periods to provide investors with
an understanding of variability and potential trends in cash flows. Ensure your discussion
and analysis is not merely a recitation of changes evident from the consolidated
statements of cash flows. Refer to Item 303(a) and (b) of Regulation S-K and SEC
Release No. 33-8350.
March 4, 2026
Page 2
Notes to Consolidated Financial Statements
Note 11 - Segment Reporting, page 62
2.You disclose the CODM utilizes operating income in evaluating performance and
allocating resources but not how the measure is used for these purposes. Refer to ASC
280-10-50-29(f) and ASC 280-10-55-47(bb). Please revise as appropriate.
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, action or
absence of action by the staff.
Please contact Robert Shapiro at 202-551-3273 or Doug Jones at 202-551-3309 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services