SEC Comment Letter 0000000000-24-005952 to Aptiv PLC (APTV) (CIK 0001521332) (APTV)
Aptiv PLC (APTV) (CIK 0001521332)
Date: May 22, 2024 · CIK: 0001521332 · Accession: 0000000000-24-005952
AI Filing Summary & Sentiment
File numbers found in text: 001-35346
Letter
United States securities and exchange commission logo May 22, 2024 Joseph Massaro Chief Financial Officer Aptiv PLC 5 Hanover Quay, Grand Canal Dock Dublin, D02 VY79, Ireland Re:Aptiv PLC Form 10-K for the Fiscal Year Ended December 31, 2023 Filed February 6, 2024 Form 8-K Furnished January 31, 2024 File No. 001-35346 Dear Joseph Massaro: We have reviewed your May 13, 2024 response to our comment letter and have the following comments Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 1, 2024 letter. Form 10-K for the Fiscal Year Ended December 31, 2023 Notes to Consolidated Financial Statements 2. Significant Accounting Policies, Revenue Recognition, page 71 1.We note within your response to comment 2 that you recognize upfront payments to customers without contractual volume guarantees as a reduction of revenue at the time of the commitment to make the payment. Please tell us in further detail how you determined such accounting treatment was more appropriate than recognizing the reduction of revenue as the related goods are transferred to customers. In doing so, ensure you explain the underlying economic reasons for the payments, your history of recovering the payments, including your history of renewals and average customer lives, whether the payments secure an exclusivity agreement with customers or provide other contractual assurances, whether the payments are expected to recur with the same customer, and whether the related supply contracts have specified lives.
FirstName LastNameJoseph Massaro Comapany NameAptiv PLC May 22, 2024 Page 2 FirstName LastName Joseph Massaro Aptiv PLC May 22, 2024 Page 2 Form 8-K Furnished January 31, 2024 Exhibit 99.1, page 1 2.We note your response to comment 7 indicates that net income attributable to Aptiv and the related margin are the most directly comparable GAAP measures to Adjusted Operating Income and Adjusted Operating Income margin. Please tell us how you determined operating income and operating income margin were not the most directly comparable GAAP measures. Please contact Eiko Yaoita Pyles at 202-551-3587 or Andrew Blume at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
May 22, 2024
Joseph Massaro
Chief Financial Officer
Aptiv PLC
5 Hanover Quay, Grand Canal Dock
Dublin, D02 VY79, Ireland
Re:Aptiv PLC
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed February 6, 2024
Form 8-K Furnished January 31, 2024
File No. 001-35346
Dear Joseph Massaro:
We have reviewed your May 13, 2024 response to our comment letter and have the
following comments
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our May 1, 2024 letter.
Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
2. Significant Accounting Policies, Revenue Recognition, page 71
1.We note within your response to comment 2 that you recognize upfront payments to
customers without contractual volume guarantees as a reduction of revenue at the time of
the commitment to make the payment. Please tell us in further detail how you determined
such accounting treatment was more appropriate than recognizing the reduction of
revenue as the related goods are transferred to customers. In doing so, ensure you explain
the underlying economic reasons for the payments, your history of recovering the
payments, including your history of renewals and average customer lives, whether the
payments secure an exclusivity agreement with customers or provide other contractual
assurances, whether the payments are expected to recur with the same customer, and
whether the related supply contracts have specified lives.
FirstName LastNameJoseph Massaro
Comapany NameAptiv PLC
May 22, 2024 Page 2
FirstName LastName
Joseph Massaro
Aptiv PLC
May 22, 2024
Page 2
Form 8-K Furnished January 31, 2024
Exhibit 99.1, page 1
2.We note your response to comment 7 indicates that net income attributable to Aptiv and
the related margin are the most directly comparable GAAP measures to Adjusted
Operating Income and Adjusted Operating Income margin. Please tell us how you
determined operating income and operating income margin were not the most directly
comparable GAAP measures.
Please contact Eiko Yaoita Pyles at 202-551-3587 or Andrew Blume at 202-551-3254 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing