SEC Comment Letter for Phillips 66 (PSX) (CIK 0001534701) (PSX) — Oct 17, 2017
Phillips 66 (PSX) (CIK 0001534701)
Date: Oct. 17, 2017 · CIK: 0001534701 · Accession: 0000000000-17-036670
AI Filing Summary & Sentiment
Letter
Mail Stop 4628 October 17 , 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 Response Dated September 22, 2017 File No. 001 -35349
Dear Mr. Oyolu :
We have reviewed your September 22, 2017 response to our comment letter 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 comm ent 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. Unless we note otherwise, our reference to the prior comment is to the comment in our Septe mber 14, 2017 letter.
Form 10 -K for Fiscal Year Ended December 31, 2016
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 30
Results of Operations, page 33
1. We have read your response to prior commen t one in which you provide details of how marketing fuel margin, refining margin and realized refining margin are calculated on a per barrel basis. Further, we note on a prospective basis you intend to include a definition and calculation for each of thes e measures in your filings. Please include details of how the amounts used in the calculations are derived from your financial statements and related note disclosures. In addition, please indicate these margin measures are not comparable to GAAP gross ma rgin or gross profit as you subtract some
Chukwuemeka A. Oyolu Phillips 66 October 17 , 2017 Page 2
but not all of the expenses that comprise a complete cost of sales measure from revenue in your calculations.
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 October 17 , 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 Response Dated September 22, 2017 File No. 001 -35349 Dear Mr. Oyolu : We have reviewed your September 22, 2017 response to our comment letter 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 comm ent 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. Unless we note otherwise, our reference to the prior comment is to the comment in our Septe mber 14, 2017 letter. Form 10 -K for Fiscal Year Ended December 31, 2016 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 30 Results of Operations, page 33 1. We have read your response to prior commen t one in which you provide details of how marketing fuel margin, refining margin and realized refining margin are calculated on a per barrel basis. Further, we note on a prospective basis you intend to include a definition and calculation for each of thes e measures in your filings. Please include details of how the amounts used in the calculations are derived from your financial statements and related note disclosures. In addition, please indicate these margin measures are not comparable to GAAP gross ma rgin or gross profit as you subtract some Chukwuemeka A. Oyolu Phillips 66 October 17 , 2017 Page 2 but not all of the expenses that comprise a complete cost of sales measure from revenue in your calculations. 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