SEC Company Response from MPLX LP (MPLX, MPLXP) (CIK 0001552000) (MPLX) — May 14, 2021
MPLX LP (MPLX, MPLXP) (CIK 0001552000)
Date: May 14, 2021 · CIK: 0001552000 · Accession: 0001552000-21-000028
AI Filing Summary & Sentiment
File numbers found in text: 001-35714
Referenced dates: May 7, 2021
Letter
Document
May 14, 2021
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
100 F Street, NE
Washington, D.C. 20549
RE: MPLX LP Form 10-K for the Fiscal Year Ended December 31, 2020 Filed February 26, 2021 File No. 001-35714
Ladies and Gentlemen:
MPLX LP, a Delaware limited partnership (the “Company”), is in receipt of the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in the Commission’s letter, dated May 7, 2021 (the “Comment Letter”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2020.
Below is the Company’s response to the Staff’s comment in the Comment Letter. For the convenience of the Staff, we have repeated the Staff’s comment before our response.
Form 10-K for the Fiscal Year Ended December 31, 2020
1. We have read your disclosure on page 87 that states, “We believe that transactions with related parties are conducted under terms comparable to those with unrelated parties.” This appears to imply that the related party transactions are conducted on an arm’s length basis. Representations about transactions with related parties shall not imply that related party transactions were consummated on terms equivalent to those that prevail in arm’s length transactions unless such representations can be substantiated. Revise your disclosure to either substantiate your belief or remove this assertion, as appropriate. Refer to ASC 850-10-50-5.
Response:
In future filings, the Company will not include language representing that such transactions were carried out on terms equivalent with arm’s length transactions unless it substantiates such claims pursuant to ASC 850-10-50-5.
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
May 14, 2021
Page 2
* * * * *
If you have any questions regarding these matters, please do not hesitate to contact the undersigned at 419.429.5640 or by email at pkbeall@marathonpetroleum.com.
Sincerely,
MPLX LP
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CORRESP 1 filename1.htm Document May 14, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation 100 F Street, NE Washington, D.C. 20549 RE: MPLX LP Form 10-K for the Fiscal Year Ended December 31, 2020 Filed February 26, 2021 File No. 001-35714 Ladies and Gentlemen: MPLX LP, a Delaware limited partnership (the “Company”), is in receipt of the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in the Commission’s letter, dated May 7, 2021 (the “Comment Letter”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2020. Below is the Company’s response to the Staff’s comment in the Comment Letter. For the convenience of the Staff, we have repeated the Staff’s comment before our response. Form 10-K for the Fiscal Year Ended December 31, 2020 1. We have read your disclosure on page 87 that states, “We believe that transactions with related parties are conducted under terms comparable to those with unrelated parties.” This appears to imply that the related party transactions are conducted on an arm’s length basis. Representations about transactions with related parties shall not imply that related party transactions were consummated on terms equivalent to those that prevail in arm’s length transactions unless such representations can be substantiated. Revise your disclosure to either substantiate your belief or remove this assertion, as appropriate. Refer to ASC 850-10-50-5. Response: In future filings, the Company will not include language representing that such transactions were carried out on terms equivalent with arm’s length transactions unless it substantiates such claims pursuant to ASC 850-10-50-5. U.S. Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation May 14, 2021 Page 2 * * * * * If you have any questions regarding these matters, please do not hesitate to contact the undersigned at 419.429.5640 or by email at pkbeall@marathonpetroleum.com. Sincerely, MPLX LP By: MPLX GP LLC, its General Partner By: /s/ Pamela K.M. Beall Name: Pamela K.M. Beall Title: Executive Vice President and Chief Financial Officer