SEC Comment Letter 0000000000-23-007579 to MEXICAN ECONOMIC DEVELOPMENT INC (FMX)
MEXICAN ECONOMIC DEVELOPMENT INC
Date: July 17, 2023 · CIK: 0001061736 · Accession: 0000000000-23-007579
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35934
Letter
United States securities and exchange commission logo July 17, 2023 Alejandro Ortiz General Counsel Mexican Economic Development, Inc. General Anaya No. 601 Pte. Colonia Bella Vista Monterrey, Nuevo León 64410, México Re:Mexican Economic Development, Inc. Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 24, 2023 File No. 001-35934 Dear Alejandro Ortiz: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2022 Financial Statements Note 3.18 Intangible Assets, page F-33 1.We note your accounting policy and disclosures regarding your treatment of TCCC bottling agreement intangible assets as indefinite lived intangible assets even though they have a stated term of 10 years and contain a 10 year renewal right. We also note your policy may be inconsistent with other entities with similar assets. Please refer to paragraph 94 of IAS 38 and more fully explain to us why you believe your accounting policy is appropriate and consistent with IFRS, given the stated term of the agreements. In addition, please explain to us the process and expected costs of renewing the agreements at the end of their 10 year term and how you concluded renewals are essentially perpetual in nature.
FirstName LastNameAlejandro Ortiz Comapany NameMexican Economic Development, Inc. July 17, 2023 Page 2 FirstName LastName Alejandro Ortiz Mexican Economic Development, Inc. July 17, 2023 Page 2 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. You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at 202-551-3723 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
United States securities and exchange commission logo
July 17, 2023
Alejandro Ortiz
General Counsel
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, Nuevo León 64410, México
Re:Mexican Economic Development, Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 24, 2023
File No. 001-35934
Dear Alejandro Ortiz:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Financial Statements
Note 3.18 Intangible Assets, page F-33
1.We note your accounting policy and disclosures regarding your treatment of TCCC
bottling agreement intangible assets as indefinite lived intangible assets even though they
have a stated term of 10 years and contain a 10 year renewal right. We also note your
policy may be inconsistent with other entities with similar assets. Please refer
to paragraph 94 of IAS 38 and more fully explain to us why you believe your accounting
policy is appropriate and consistent with IFRS, given the stated term of the agreements.
In addition, please explain to us the process and expected costs of renewing
the agreements at the end of their 10 year term and how you concluded renewals are
essentially perpetual in nature.
FirstName LastNameAlejandro Ortiz
Comapany NameMexican Economic Development, Inc.
July 17, 2023 Page 2
FirstName LastName
Alejandro Ortiz
Mexican Economic Development, Inc.
July 17, 2023
Page 2
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.
You may contact Dale Welcome at 202-551-3865 or Kevin Stertzel at 202-551-3723 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing