SEC Comment Letter for Murphy USA Inc. (MUSA) (CIK 0001573516) (MUSA) — May 6, 2020
Murphy USA Inc. (MUSA) (CIK 0001573516)
Date: May 6, 2020 · CIK: 0001573516 · Accession: 0000000000-20-003953
AI Filing Summary & Sentiment
File numbers found in text: 001-35914
Letter
United States securities and exchange commission logo May 6, 2020 Mindy K. West Principal Financial Officer Murphy USA Inc. 200 Peach Street El Dorado, Arkansas 71730 Re:Murphy USA Inc. Form 10-K for the Year Ended December 31, 2019 Filed February 18, 2020 File No. 001-35914 Dear Ms. West: We have limited our review of your filing to the financial statements and related disclosures 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 business days by providing the requested information or advise 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. Form 10-K for the Year Ended December 31, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Operating Activities, page 35 1.Your analysis of changes in operating cash flows here and in the Form 10-Q for the period ended March 31, 2020 cites net income (which is on the the accrual basis) and noncash items in explaining the change in cash. Note that citing such items may not provide a sufficient basis to understand how and why actual operating cash varied between comparable periods. Please refer to section IV.B.1 of SEC Release No. 33-8350 for guidance and revise your disclosure as appropriate. In closing, 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.
FirstName LastNameMindy K. West Comapany NameMurphy USA Inc. May 6, 2020 Page 2 FirstName LastName Mindy K. West Murphy USA Inc. May 6, 2020 Page 2 You may contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
May 6, 2020
Mindy K. West
Principal Financial Officer
Murphy USA Inc.
200 Peach Street
El Dorado, Arkansas 71730
Re:Murphy USA Inc.
Form 10-K for the Year Ended December 31, 2019
Filed February 18, 2020
File No. 001-35914
Dear Ms. West:
We have limited our review of your filing to the financial statements and related
disclosures 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 business days by providing the requested
information or advise 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.
Form 10-K for the Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Operating Activities, page 35
1.Your analysis of changes in operating cash flows here and in the Form 10-Q for the period
ended March 31, 2020 cites net income (which is on the the accrual basis) and noncash
items in explaining the change in cash. Note that citing such items may not provide a
sufficient basis to understand how and why actual operating cash varied between
comparable periods. Please refer to section IV.B.1 of SEC Release No. 33-8350 for
guidance and revise your disclosure as appropriate.
In closing, 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.
FirstName LastNameMindy K. West
Comapany NameMurphy USA Inc.
May 6, 2020 Page 2
FirstName LastName
Mindy K. West
Murphy USA Inc.
May 6, 2020
Page 2
You may contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services