Form S-4
2020-11-16 to 2020-11-16 · 2 questions
· 1 letter from the SEC, 0 from the company
Non-GAAP measuresLiquidity and cash
SEC letter of 2020-11-16 ↗
no reply letter on EDGAR (the company may have answered in an amended filing)
Recommendation of the WPX Board and its Reasons for the Merger, page 73
SEC asked (1)
Disclosure in this section states that the WPX Board considered the implementation of a "Fixed Plus Variable" dividend strategy in recommending that WPX stockholders vote for the Merger Proposal. We also note Devon Energy's Form 10-Q for the quarterly period ended September 30, 2020 states that upon closing of the Merger it intends to implement a fixed plus variable dividend strategy, with variable dividends up toRest of the question
50% of excess quarterly free cash, subject to certain criteria. Please expand your disclosure to discuss the criteria for the payment of the variable dividend and clarify how you expect the combined company to compute "excess free cash flow" in determining such variable dividend.
DVN answered
No reply letter found.
General
SEC asked (2)
Please be advised that we will not be in a position to declare this registration statement effective until you have resolved all comments on your Exchange Act reports. Please refer to the comment letter dated November 16, 2020 regarding your annual report on Form 10-K for the fiscal year ended December 31, 2019.
DVN answered
No reply letter found.
