SEC Comment Letter for Phillips 66 (PSX) (CIK 0001534701) (PSX) — Sep 14, 2017
Phillips 66 (PSX) (CIK 0001534701)
Date: Sept. 14, 2017 · CIK: 0001534701 · Accession: 0000000000-17-032684
AI Filing Summary & Sentiment
Letter
Mail Stop 4628 September 14, 2017 Mr. Chukwuemeka A. Oyolu Vice President and Controller Phillips 66 2331 CityWest Blvd. Houston, TX 77042
Re: Phillips 66 Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 17, 2017 File No. 001 -35349
Dear Mr. Oyolu :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment . 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 comment 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 comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2016
Management’s Discu ssion and Analysis of Financial Condition and Results of Operations, page 30
Results of Operations, page 33
1. We note you present Refining Margins and Realized Marketing Fuel Margins both on a per barrel basis in your Segments Results discussion. Please provide a definition and calculation of these measures. If such measures do not align with a GAAP measure, please tell us what consideration you gave to identifying them as non -GAAP and providing the information set forth in Item 10(e) of Regulation S -K.
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.
Chukwuemeka A. Oyolu Phillips 66 September 14, 2017 Page 2
You may contact Jenifer Gallagher, Staff Accountant at (202) 551 -3706 or me at (202) 551-3489 with any questions.
Sincerely,
/s/ Brad Skinner
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Mail Stop 4628 September 14, 2017 Mr. Chukwuemeka A. Oyolu Vice President and Controller Phillips 66 2331 CityWest Blvd. Houston, TX 77042 Re: Phillips 66 Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 17, 2017 File No. 001 -35349 Dear Mr. Oyolu : We have limited our review of your filing to the financial statements and related disclosures and have the following comment . 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 comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2016 Management’s Discu ssion and Analysis of Financial Condition and Results of Operations, page 30 Results of Operations, page 33 1. We note you present Refining Margins and Realized Marketing Fuel Margins both on a per barrel basis in your Segments Results discussion. Please provide a definition and calculation of these measures. If such measures do not align with a GAAP measure, please tell us what consideration you gave to identifying them as non -GAAP and providing the information set forth in Item 10(e) of Regulation S -K. 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. Chukwuemeka A. Oyolu Phillips 66 September 14, 2017 Page 2 You may contact Jenifer Gallagher, Staff Accountant at (202) 551 -3706 or me at (202) 551-3489 with any questions. Sincerely, /s/ Brad Skinner Brad Skinner Senior Assistant Chief Accountant Office of Natural Resources