SEC Comment Letter for Cencora, Inc. (COR) (CIK 0001140859) (COR) — Mar 17, 2015
Cencora, Inc. (COR) (CIK 0001140859)
Date: March 17, 2015 · CIK: 0001140859 · Accession: 0000000000-15-015523
AI Filing Summary & Sentiment
Referenced dates: February 24, 2015
Letter
March 17 , 2015 Via E -Mail Mr. Tim G. Guttman Chief Financial Officer AmerisourceBergen Corporation 1300 Morris Drive Chesterbrook, PA 19087 -5594
Re: AmerisourceBergen Corporation Form 10 -K for the Fiscal Year Ended September 30, 2014 Filed November 25, 2014 Response dated March 9, 2015 File No. 001- 16671
Dear Mr . Guttman :
We have reviewed your response letter and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing s, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your respons e.
After reviewing any amendment to your filings and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended September 30, 2014
Management’s Discussion and Analy sis of Financial Condition and Results of Operations, page 23
Results of Operations, page 24
Year ended September 30, 2014 compared with Year ended September 30, 2013, page 24
Gross Profit, page 25
1. We note in your response to comment two of our letter dated February 24, 2015 that you believe the effect of changes in the allowance for sales returns is immaterial to gross profit. Please quantify for us the effect of the fiscal 2014 and first quarter 2015
Tim G. Guttman AmerisourceBergen Corporation March 17 , 2015 Page 2
changes that are included in your gross profit, and further explain to us why you believe these are immaterial to gross profit and do not require separate disclosure to quantify the effects. Alternatively, confirm that you will include such disclosure in future fil ings, to the extent the effects are significant, and provide us with your draft disclosure based on the effect of the fiscal 2014 and first quarter 2015 changes.
You may contact Joanna Lam at (202) 551 -3476 or John Archfield at (202) 551 - 3315 if you have questions regarding comments on the financial s tatements and related matters.
Sincerely,
/s/Tia L. Jenkins
Show Raw Text
March 17 , 2015
Via E -Mail
Mr. Tim G. Guttman
Chief Financial Officer
AmerisourceBergen Corporation
1300 Morris Drive
Chesterbrook, PA 19087 -5594
Re: AmerisourceBergen Corporation
Form 10 -K for the Fiscal Year Ended September 30, 2014
Filed November 25, 2014
Response dated March 9, 2015
File No. 001- 16671
Dear Mr . Guttman :
We have reviewed your response letter and have the following comment. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing s, by
providing the requested information, or by advising us when you will provide the requested
response. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your respons e.
After reviewing any amendment to your filings and the information you provide in
response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended September 30, 2014
Management’s Discussion and Analy sis of Financial Condition and Results of Operations,
page 23
Results of Operations, page 24
Year ended September 30, 2014 compared with Year ended September 30, 2013, page 24
Gross Profit, page 25
1. We note in your response to comment two of our letter dated February 24, 2015 that
you believe the effect of changes in the allowance for sales returns is immaterial to
gross profit. Please quantify for us the effect of the fiscal 2014 and first quarter 2015
Tim G. Guttman
AmerisourceBergen Corporation
March 17 , 2015
Page 2
changes that are included in your gross profit, and further explain to us why you
believe these are immaterial to gross profit and do not require separate disclosure to
quantify the effects. Alternatively, confirm that you will include such disclosure in
future fil ings, to the extent the effects are significant, and provide us with your draft
disclosure based on the effect of the fiscal 2014 and first quarter 2015 changes.
You may contact Joanna Lam at (202) 551 -3476 or John Archfield at (202) 551 - 3315 if
you have questions regarding comments on the financial s tatements and related matters.
Sincerely,
/s/Tia L. Jenkins
Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining