SEC Comment Letter for Western Midstream Partners, LP (WES) (CIK 0001423902) (WES) — Aug 3, 2021
Western Midstream Partners, LP (WES) (CIK 0001423902)
Date: Aug. 3, 2021 · CIK: 0001423902 · Accession: 0000000000-21-009502
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34046, 001-35753
Letter
United States securities and exchange commission logo August 3, 2021 Michael P. Ure President and Chief Executive Officer Western Midstream Partners, LP 9950 Woodloch Forest Drive, Suite 2800 The Woodlands, Texas 77380 Re:Western Midstream Partners, LP and Western Midstream Operating, LP Form 10-K for the Fiscal Year Ended December 31, 2020 Filed February 26, 2021 File Nos. 001-35753 and 001-34046 Dear Mr. Ure: 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 the 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 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, 2020 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP financial measures, page 72 1.We note you present Adjusted Gross Margin as a non-GAAP measure and that you reconcile this measure to operating income at page 73. Please revise to reconcile to a fully loaded GAAP gross profit or tell us why you believe operating income is the most directly comparable GAAP measure. Refer to Item 10(e)(1)(i)(B) of Regulation S-K.
FirstName LastNameMichael P. Ure Comapany NameWestern Midstream Partners, LP August 3, 2021 Page 2 FirstName LastName Michael P. Ure Western Midstream Partners, LP August 3, 2021 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 Joanna Lam, Staff Accountant at 202-551-3476 or Craig Arakawa, Branch Chief at 202-551-3650 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
August 3, 2021
Michael P. Ure
President and Chief Executive Officer
Western Midstream Partners, LP
9950 Woodloch Forest Drive, Suite 2800
The Woodlands, Texas 77380
Re:Western Midstream Partners, LP and
Western Midstream Operating, LP
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed February 26, 2021
File Nos. 001-35753 and 001-34046
Dear Mr. Ure:
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 the 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
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, 2020
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP financial measures, page 72
1.We note you present Adjusted Gross Margin as a non-GAAP measure and that you
reconcile this measure to operating income at page 73. Please revise to reconcile to a fully
loaded GAAP gross profit or tell us why you believe operating income is the most directly
comparable GAAP measure. Refer to Item 10(e)(1)(i)(B) of Regulation S-K.
FirstName LastNameMichael P. Ure
Comapany NameWestern Midstream Partners, LP
August 3, 2021 Page 2
FirstName LastName
Michael P. Ure
Western Midstream Partners, LP
August 3, 2021
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 Joanna Lam, Staff Accountant at 202-551-3476 or Craig Arakawa,
Branch Chief at 202-551-3650 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation