SEC Comment Letter for CONOCOPHILLIPS (COP) (CIK 0001163165) (COP) — Sep 26, 2012
CONOCOPHILLIPS (COP) (CIK 0001163165)
Date: Sept. 26, 2012 · CIK: 0001163165 · Accession: 0000000000-12-052931
AI Filing Summary & Sentiment
Referenced dates: August 3, 2012, July 20, 2012
Letter
September 26, 2012 Via E -mail Mr. Jeff W. Sheets Chief Financial Officer ConocoPhillips 600 North Dairy Ashford Houston, TX 77079
Re: ConocoPhillips Form 10 -K for the Fiscal Year ended December 31, 2011 Filed February 21, 2012 Response Letter Dated August 3, 2012 File No. 1-32395
Dear M r. Sheets :
We have reviewed your response letter and 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, w e may have additional comments.
Annual Report on Form 10 -K for the Fiscal Year Ended December 31, 2011
Risk Factors, page 31
Our operations present hazards and risks that require significant and continuous oversight, page 33
1. We note your response to prior comment 2 from our letter to you dated July 20, 2012. In future filings, beginning with your next Form 10 -Q, please provide a separate discussion of the risks posed to your operations from your dependence upon technology or to your business, operations or reputation by cyber attacks or breaches of your cybersecurity. In addition, in order to provide the proper context for your risk factor disclosure, and as you stated in your response letter, please confirm that you will dis close in this revised risk factor that you have experienced occasional actual and attempted breaches of your cybersecurity.
Mr. Jeff W. Sheets ConocoPhillips September 26, 2012 Page 2
Financial Statements and Supplementary Data, page 77
Supplementary Information - Oil and Gas Operations, page 140
Proved Undevelop ed Reserves, page 149
2. Your response to prior comment number 4 from our letter dated July 20, 2012 indicates, in part, that future development costs, as shown in your presentation of SMOG, includes not only costs related to the development of proved undeve loped reserves, but also includes costs associated with sustaining existing producing reserves (“sustaining costs”) and costs associated with the abandonment of the developed assets (“abandonment costs”). Supplementally, tell us the amount of “sustaining costs” and “abandonment costs” included in future development costs per your presentation of SMOG as of December 31, 2011, by year for the first five years and in total. Also, describe for us in greater detail the nature of the “sustaining costs”, and exp lain to us the specific types of actions or activities to which they relate. Finally, explain your accounting policies for “sustaining costs.”
You may contact John Cannarella , Staff Accountant, at (202) 551 -3337 or Bradshaw Skinner , Senior Assistant Chief Ac countant , at (202) 551 -3489 if you have questions regarding comments on the financial s tatements and related matters. Please contact Caroline Kim, Staff Attorney, at (202) 551 -3878 or , Laura Nicholson , Staff Attorney , at (202) 551 - 3584 with any other questions.
Sincerely,
/s/H. Roger Schwall
Show Raw Text
September 26, 2012
Via E -mail
Mr. Jeff W. Sheets
Chief Financial Officer
ConocoPhillips
600 North Dairy Ashford
Houston, TX 77079
Re: ConocoPhillips
Form 10 -K for the Fiscal Year ended December 31, 2011
Filed February 21, 2012
Response Letter Dated August 3, 2012
File No. 1-32395
Dear M r. Sheets :
We have reviewed your response letter and 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, w e may have additional comments.
Annual Report on Form 10 -K for the Fiscal Year Ended December 31, 2011
Risk Factors, page 31
Our operations present hazards and risks that require significant and continuous oversight,
page 33
1. We note your response to prior comment 2 from our letter to you dated July 20, 2012. In
future filings, beginning with your next Form 10 -Q, please provide a separate discussion
of the risks posed to your operations from your dependence upon technology or to your
business, operations or reputation by cyber attacks or breaches of your cybersecurity. In
addition, in order to provide the proper context for your risk factor disclosure, and as you
stated in your response letter, please confirm that you will dis close in this revised risk
factor that you have experienced occasional actual and attempted breaches of your
cybersecurity.
Mr. Jeff W. Sheets
ConocoPhillips
September 26, 2012
Page 2
Financial Statements and Supplementary Data, page 77
Supplementary Information - Oil and Gas Operations, page 140
Proved Undevelop ed Reserves, page 149
2. Your response to prior comment number 4 from our letter dated July 20, 2012 indicates,
in part, that future development costs, as shown in your presentation of SMOG, includes
not only costs related to the development of proved undeve loped reserves, but also
includes costs associated with sustaining existing producing reserves (“sustaining costs”)
and costs associated with the abandonment of the developed assets (“abandonment
costs”). Supplementally, tell us the amount of “sustaining costs” and “abandonment
costs” included in future development costs per your presentation of SMOG as of
December 31, 2011, by year for the first five years and in total. Also, describe for us in
greater detail the nature of the “sustaining costs”, and exp lain to us the specific types of
actions or activities to which they relate. Finally, explain your accounting policies for
“sustaining costs.”
You may contact John Cannarella , Staff Accountant, at (202) 551 -3337 or Bradshaw
Skinner , Senior Assistant Chief Ac countant , at (202) 551 -3489 if you have questions regarding
comments on the financial s tatements and related matters. Please contact Caroline Kim, Staff
Attorney, at (202) 551 -3878 or , Laura Nicholson , Staff Attorney , at (202) 551 - 3584 with any
other questions.
Sincerely,
/s/H. Roger Schwall
H. Roger Schwall
Assistant Director