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DEDeere & Company

Industrials · Farm Machinery · NYSE
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SEC comment letters, last 20 years

1 review of DE's filings by SEC staff

UPLOAD and CORRESP
ReviewsRead ↓
1
latest letter 2020-09-29
Questions asked
2
each answered in the company's own letter
No closing letter
0
reviews without a letter saying the staff completed it

When the SEC's staff reviews a filing, it writes to the company with numbered questions, and the company answers each one in a letter. SEC publishes the exchange once the review is over, at least 20 business days later. A question is not an accusation; most reviews end with the company adding detail to its next filing.

Form 10-Q

2020-09-29 to 2020-11-02 · 2 questions · 2 letters from the SEC, 3 from the company
Review closed 2020-11-02
Non-GAAP measuresSegments
Condensed Notes to Interim Consolidated Financial Statements (Unaudited) · Note 21. Supplemental Consolidating Data, page 42
SEC asked
Please tell us the purpose of these supplemental schedules, what they reconcile to and why they are included in the footnotes to the financial statements. As part of your response, explain your basis for including the Financial Services segment using the equity method of accounting in your presentation of Equipment Operations and tell us how you considered Question 100.04 of the Non-GAAP Compliance and Disclosure
Rest of the question

Interpretations.

DE answered

No numbered answer found in the reply. Read the reply ↗

In its next report

First report after the company's reply of 2020-10-13: 10-K filed 2020-12-17 ↗, against the 10-K filed 2019-12-19 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Condensed Notes to Interim Consolidated Financial Statements (Unaudited) · Note 21. Supplemental Consolidating Data, page 42
SEC asked
We note your response to prior comment 1. We continue to believe that including the Financial Services segment using the equity method of accounting in your presentation of Equipment Operations is a tailored accounting principle under Question 100.04 of the Non-GAAP Compliance and Disclosure Interpretations. Please remove this presentation in future filings.
DE answered
Deere & Company (“Deere” or the “Company”) has received the response from the Division of Corporation Finance of the Securities and Exchange Commission, dated October 15, 2020, pertaining to the Company’s response to the earlier comment on the Company’s Form 10-Q for the quarterly period ended August 2, 2020. As you know, we are working on the Company’s response and we respectfully request additional time to complete this review. We anticipate responding on or before November 12, 2020. Read in the reply ↗
In its next report

First report after the company's reply of 2020-10-28: 10-K filed 2020-12-17 ↗, against the 10-K filed 2019-12-19 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Also in this review: company letter, 2020-10-30, closing letter, 2020-11-02

From the SEC's correspondence on EDGAR: staff letters (form UPLOAD) and company letters (form CORRESP), 21 letters filed since 2016-01-27. Questions and answers are matched by their numbers; topics come from words in each question. The reports are compared word for word (same form, before the first SEC letter against the first report after the company's reply). No AI.

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