SEC Comment Letter for CF Industries Holdings, Inc. (CF) (CIK 0001324404) (CF) — Dec 30, 2020
CF Industries Holdings, Inc. (CF) (CIK 0001324404)
Date: Dec. 30, 2020 · CIK: 0001324404 · Accession: 0000000000-20-012593
AI Filing Summary & Sentiment
File numbers found in text: 001-32597
Letter
United States securities and exchange commission logo December 30, 2020 Christopher D. Bohn Senior Vice President and Chief Financial Officer CF Industries Holdings, Inc. 4 Parkway North, Suite 400 Deerfield, IL 60015 Re:CF Industries Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 24, 2020 File No. 001-32597 Dear Mr. Bohn: We have reviewed your filing 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2019 Item 11. Executive Compensation, page 129 1.We note the discussion of executive compensation in your proxy statement does not discuss the impact your share repurchases have on RONA and TSR. Please confirm that your future filings will discuss this impact on these measures and consequently on the vesting of your long term incentive awards or provide us with an analysis supporting your determination that the impact is not material. 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 Ameen Hamady at 202-551-3891 or Daniel Gordon at 202-551-3486 if you have questions regarding comments on the financial statements and related matters. Please contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at 202-551-3675 with any other
FirstName LastNameChristopher D. Bohn Comapany NameCF Industries Holdings, Inc. December 30, 2020 Page 2 FirstName LastName Christopher D. Bohn CF Industries Holdings, Inc. December 30, 2020 Page 2 questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Douglas C. Barnard
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United States securities and exchange commission logo
December 30, 2020
Christopher D. Bohn
Senior Vice President and Chief Financial Officer
CF Industries Holdings, Inc.
4 Parkway North, Suite 400
Deerfield, IL 60015
Re:CF Industries Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 24, 2020
File No. 001-32597
Dear Mr. Bohn:
We have reviewed your filing 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Item 11. Executive Compensation, page 129
1.We note the discussion of executive compensation in your proxy statement does not
discuss the impact your share repurchases have on RONA and TSR. Please confirm that
your future filings will discuss this impact on these measures and consequently on the
vesting of your long term incentive awards or provide us with an analysis supporting your
determination that the impact is not material.
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 Ameen Hamady at 202-551-3891 or Daniel Gordon at 202-551-3486 if
you have questions regarding comments on the financial statements and related matters. Please
contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at 202-551-3675 with any other
FirstName LastNameChristopher D. Bohn
Comapany NameCF Industries Holdings, Inc.
December 30, 2020 Page 2
FirstName LastName
Christopher D. Bohn
CF Industries Holdings, Inc.
December 30, 2020
Page 2
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Douglas C. Barnard