SEC Comment Letter for CME GROUP INC. (CME) (CIK 0001156375) (CME) — May 30, 2014
CME GROUP INC. (CME) (CIK 0001156375)
Date: May 30, 2014 · CIK: 0001156375 · Accession: 0000000000-14-027611
AI Filing Summary & Sentiment
Reasoning
Letter
May 30, 2014 Via E -Mail James E. Parisi Chief Financial Officer CME Group Inc. 20 South Wacker Drive Chicago, IL 60606
Re: CME Group Inc. Form 10 -K for the Fiscal Ye ar Ended December 31, 20 13 Filed March 3, 2014 File No. 001 -31553
Dear Mr. Parisi :
We have reviewed your filing an d 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 this letter within ten business days by amending your filing, 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 response .
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 201 3 filed March 3 , 201 4
Cash Requirements , page 46
1. We note your disclosure on page 47 that debt obligations include repayment of the debt obligation as well as interest payments associated with the debt obligations. We also note that the amount of debt obligations included within the contractual obligation s table on page 46 approximates the principal amount disclosed in note 8 on page 71. Please tell us the amount of interest payments included in your contractual obligations table, the contractual terms of your debt agreements relating to interest payments, and reconcile to the disclosure in note 8.
James E. Parisi CME Group Inc. May 30, 2014 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In res ponding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have any questions, you may contact Jorge L. Bonilla at (202) 551 -3414 or me at (202) 551 -3486.
Sincerely,
/s/ Daniel L. Gordon
Show Raw Text
May 30, 2014
Via E -Mail
James E. Parisi
Chief Financial Officer
CME Group Inc.
20 South Wacker Drive
Chicago, IL 60606
Re: CME Group Inc.
Form 10 -K for the Fiscal Ye ar Ended December 31, 20 13
Filed March 3, 2014
File No. 001 -31553
Dear Mr. Parisi :
We have reviewed your filing an d 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 this letter within ten business days by amending your filing, 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
response .
After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 201 3 filed March 3 , 201 4
Cash Requirements , page 46
1. We note your disclosure on page 47 that debt obligations include repayment of
the debt obligation as well as interest payments associated with the debt
obligations. We also note that the amount of debt obligations included within the
contractual obligation s table on page 46 approximates the principal amount
disclosed in note 8 on page 71. Please tell us the amount of interest payments
included in your contractual obligations table, the contractual terms of your debt
agreements relating to interest payments, and reconcile to the disclosure in note 8.
James E. Parisi
CME Group Inc.
May 30, 2014
Page 2
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company
and its management are in possession of all facts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy of the disclosures they have made.
In res ponding to our comments, please provide a written statement from the
company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.
If you have any questions, you may contact Jorge L. Bonilla at (202) 551 -3414 or
me at (202) 551 -3486.
Sincerely,
/s/ Daniel L. Gordon
Daniel L. Gordon
Branch Chief