SEC Comment Letter for General Motors Co (GM) (CIK 0001467858) (GM) — Dec 7, 2016
General Motors Co (GM) (CIK 0001467858)
Date: Dec. 7, 2016 · CIK: 0001467858 · Accession: 0000000000-16-103927
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34960
Letter
December 7, 2016 Charles K. Stevens III Executive Vice President and Chief Financial Officer General Motors Company 300 Renaissance Center Detroit, Michigan 48265 -3000
Re: General Motors Company Form 8-K Dated July 21, 2016 Filed July 21, 2016 File No. 001-34960
Dear Mr. Stevens :
We have reviewed your October 17, 2016 response to our comment 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 these comments within ten busine ss days by providing the requested information or advis e 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. Unless we note otherwise, our references to prior comments are to comments in our Septe mber 28, 2016 letter .
Exhibit 1
General Motors Company and Subsidiaries
Supplemental Material, page 1
1. We note your response to prior comment four. Please revise future filings to supplement your presentation of ROIC -adjusted with presentati on of ROIC calculated on a non -adjusted basis using GAAP net income. Refer to 10(e)(1)(i)(A) of Regulation S -K.
Charles K. Stevens III General Motors Company December 7 , 2016 Page 2
You may contact Amy Geddes at 202 -551-3304 or me at 202-551-3380 with any questions.
Sincerely,
/s/ Lyn Shenk
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December 7, 2016 Charles K. Stevens III Executive Vice President and Chief Financial Officer General Motors Company 300 Renaissance Center Detroit, Michigan 48265 -3000 Re: General Motors Company Form 8-K Dated July 21, 2016 Filed July 21, 2016 File No. 001-34960 Dear Mr. Stevens : We have reviewed your October 17, 2016 response to our comment 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 these comments within ten busine ss days by providing the requested information or advis e 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. Unless we note otherwise, our references to prior comments are to comments in our Septe mber 28, 2016 letter . Exhibit 1 General Motors Company and Subsidiaries Supplemental Material, page 1 1. We note your response to prior comment four. Please revise future filings to supplement your presentation of ROIC -adjusted with presentati on of ROIC calculated on a non -adjusted basis using GAAP net income. Refer to 10(e)(1)(i)(A) of Regulation S -K. Charles K. Stevens III General Motors Company December 7 , 2016 Page 2 You may contact Amy Geddes at 202 -551-3304 or me at 202-551-3380 with any questions. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief Office of Transportation and Leisure