Segment reporting
7 staff comments in this corpus, to 6 registrants, filed 2023-01-10 to 2025-12-08.
Corpus in progress. This is an early build. It does not yet cover every comment letter the SEC has published, so counts here are counts within this corpus and must not be read as complete SEC-wide totals. Every quotation is verbatim and links to its filing; what is incomplete is coverage, not accuracy. See Methodology.
| Measure | Value |
|---|---|
| Comments raising this issue | 7 |
| Share of all 4,297 comments in the corpus | 0.2% |
| Distinct registrants | 6 |
| With a recorded company response | 7 |
The exchanges
SEC staff comment
3. You disclose in your segment footnote that your “CODM uses Operating Income (Loss) to evaluate income generated from segment resources in deciding whether to reinvest profits into the retail segment or into other parts of the entity, such as to make acquisitions or investments. The CODM also uses Operating Income (Loss) to monitor budget versus actual results. The monitoring of budgeted versus actual results is used in assessing performance of the segment and in establishing bonus metrics.” Please discuss in detail how this process works and incorporate your consideration of the importance of Operating Income (Loss) to your CODM into your materiality assessment. Company
The company responded
We respectfully acknowledge the Staff’s comment. The Company acknowledges that its segment footnote refers to Operating Income (Loss) as a metric shared with its Chief Operating Decision Maker (“ CODM ”). The Company currently has one reportable segment, which is its Retail business. The Retail segment comprises the Company’s Bed Bath & Beyond operating segment and Overstock.com operating segment, which are aggregated into a single reportable segment due to their similar economic characteristics and business activities. The Bed Bath & Beyond operating segment includes results from its buybuy BABY brand, and formerly also included the Zulily brand, which was sold in the first quarter of 2025, neither of which are material to the Company’s business. The Retail segment derives revenue primarily from e-commerce sales of home furnishing merchandise through the Company’s suite of websites and…
BED BATH & BEYOND, INC. · filed 2025-12-08 · 0001130713-25-000082
SEC staff comment
1. We note your tabular presentations include numerous amounts; however, it is not clear if or how the amounts presented reconcile to consolidated amounts. In this regard, please address the following in future filings: • Clarify and explain if or how the separate segment operating income (loss) amounts reconcile to consolidated operating income (loss) amounts; • Clarify and explain if or how the separate segment income (loss) from unconsolidated investments amounts reconcile to consolidated income (loss) from unconsolidated investments amounts; and • Clarify or explain why the amounts identified as Canopy equity earnings (losses) appear to represent comparable non-GAAP amounts rather than reported GAAP amounts. 207 High Point Drive, Building 100, Victor, NY 14564 Please enjoy our products responsibly. © 2020 Constellation Brands Inc., Victor, NY United States Securities and Exchange…
The company responded
The Company acknowledges the Staff’s comment. In response to the first bullet, the Company respectfully advises the Staff that consolidated operating income (loss) amounts in the Filing are calculated as (i) Beer Segment operating income (loss), plus (ii) Wine and Spirits Segment operating income (loss), plus (iii) Corporate Operations and Other Segment operating income (loss), minus (iv) Comparable Adjustments to Consolidated operating income (loss). In response to the second bullet, the Company respectfully advises the Staff that consolidated income (loss) from unconsolidated investment amounts in the Filing are calculated as (i) Wine and Spirits Segment income (loss) from unconsolidated investments, plus (ii) Corporate Operations and Other Segment income (loss) from unconsolidated investments, plus (iii) Canopy equity earnings (losses), minus (iv) Comparable Adjustments to…
CONSTELLATION BRANDS, INC. · filed 2023-03-09 · 0000016918-23-000020
SEC staff comment
5. You disclose in the note (i) the group has one operating segment which is also its only reporting segment, (ii) “As the group only has one reporting segment, all relevant financial information is disclosed in the consolidated financial statements,” and “. financial information, including Adjusted EBITDA . are only provided on a consolidated basis.” You confirm in the response you only have one operating and reportable segment and Adjusted EBITDA is presented for the company as a whole. IFRS 8 defines operating segment as a “component” (emphasis added) of an entity. It appears clear from the basis for conclusions for IFRS 8 and predecessor guidance the core principle of segment information was regarded as a disaggregation of an entity’s information. Additionally, entity-wide disclosures required by IFRS 8 for entities that have a single reportable segment do not call for an…
The company responded
The Company respectfully acknowledges the Staff’s comment. The Company believes this is an area open to interpretation and has historically interpreted the core principle within IFRS 8.1 as requiring disclosures that are based on information reported to the chief operating decision maker. Therefore, despite the lack of disaggregated financial information, the Company determined it was appropriate and consistent with IFRS 8 to disclose Adjusted EBITDA and the related required reconciliations as it represented information that enabled users of the financial statements to evaluate the nature and financial effects of the Company’s business activities in the same manner as management. Notwithstanding this view, the Company respectfully acknowledges the Staff’s interpretation of IFRS 8 and will revise its future disclosures, including in its Annual Report on Form 20-F for the year ending…
Allego N.V. · filed 2023-02-14 · 0001193125-23-039155
SEC staff comment
34. We note your response to comment 59. Please explain to us in detail how the lower-level operating results of your subsidiaries (i.e., Tranglo, TNG Asia, GEA and WalletKu) included in Management’s Discussion and Analysis of Financial Condition and Results of Operations of Seamless are not indicative of your operating segments being at a lower level than your reportable segments. Also, please provide us with your analysis on whether or not your subsidiaries (i.e., Tranglo, TNG Asia, GEA and WalletKu) represent separate operating segments as defined in ASC 280-10-50-1 through 9.
The company responded
The Company respectfully advises the Staff that each subsidiary of Seamless is an operating segment as defined by ASC 280-10-50-1 through 9. However, Seamless aggregates the operations of each into what it considers to be its reportable segments – remittance, airtime, and other. The remittance segment is operated through TNGA, GEA and Tranglo. TNGA and GEA are in the retail remittance business in Hong Kong, whereas Tranglo operates the remittance hub covering Southeast Asia and globally. Tranglo provides its services TNGA and GEA to facilitate their money transmission services for their customers, and TNGA and GEA provide transaction flows to Tranglo. As a result, when allocating resources and evaluating business results, Seamless considers the remittance business as a whole, instead of focusing on individual subsidiaries. All remittance flows of TNGA and GEA go through Tranglo, and…
InFinT Acquisition Corp · filed 2023-02-13 · 0001493152-23-004543
SEC staff comment
5. We note the analysis you provided as it relates to your presentation of Segments Revenues in response to prior comment 16 in our letter dated September 21, 2022, prior comment 3 in our letter dated December 5, 2022, and the additional information you provided to us over the phone. However, based on the guidance in IFRS 8, Operating Segments, we object to the Company’s presentation of Segments Revenues within the segment footnote, specifically the inclusion of “Proceeds from the sale of electricity, as IFRS 8.23(a) requires disclosure of “revenues from external customers,” which does not permit disclosure of amounts that are not revenue recognized in the current period. Please revise your segment disclosures accordingly.
The company responded
The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on Notes 28 and 7 accordingly. General
Enlight Renewable Energy Ltd. · filed 2023-01-31 · 0001104659-23-008655
SEC staff comment
10. We note from the disclosure on pages 2 and 90 that the ratio you disclosed is computed as an annualized total amount of Segment Adjusted EBITDA of three of your segments based on invested capital in your operational projects. Please address the following as it relates to this ratio: · Explain why you calculate an annualized performance measure on one quarter when you indicate on pages 49 and 66 that both your solar energy and wind energy projects are impacted by seasonal trends. · Describe in more detail the estimate or assumption underlying each component of the measure. For example, disclose that Segment Adjusted EBITDA includes the adjustments for the repayment of construction contracts under concession arrangements. As another example, describe how invested capital is determined.
The company responded
The Company respectfully acknowledges the Staff’s comment and advises the Staff that the Company believes that the use of an annualized total amount of Segment Adjusted EBITDA is appropriate given the rapid growth of the Company’s Operational Projects between quarters in 2022, which resulted in a rapid growth in the Company’s Segment Adjusted EBITDA in between quarters, making the use of an annualized total amount more appropriate than, for example, a trailing 12 months total amount. In addition, the Company’s geographic and technologic diversity substantially mitigates any seasonal effects. The Company respectfully advises the Staff that it has revised the disclosure on pages 2 and 92 to describe in more detail the estimate or assumption underlying each component of the measure. * * * January 20, 2023 Page 6 We hope the foregoing answers are responsive to your comments. Please do not…
Enlight Renewable Energy Ltd. · filed 2023-01-20 · 0001104659-23-005319
SEC staff comment
2. We note you disclose operating income, income before income taxes and net income (loss) for each of your reportable segments. Considering you disclose more than one measure of segment profit or loss, please revise to disclose only one measure that you believe is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amount in the consolidated statements of operations. Refer to ASC 280-10-50-28. In addition, to the extent that the measures that are not identified as the segment measure of profit or loss under ASC 280 are presented outside the consolidated financial statements, please label them as non-GAAP financial measures and provide the required disclosures under Item 10(e) of Regulation S-K.
The company responded
We have considered the Staff’s comment and will revise our disclosure in the Notes to Consolidated Financial Statements, Note 18 – Segment Information, beginning with our annual report on Form 10-K for the year ended December 31, 2022. We will revise the disclosure to disclose only one measure of segment performance that we believe to be determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amount in the consolidated statements of operations. In referring to ASC 280-10-50-28, the Company’s chief operating decision maker primarily uses one measure of a segment’s profit or loss, and the measure is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amounts in the Company’s consolidated financial statements. The measure selected to be disclosed in future…
Essential Utilities, Inc. · filed 2023-01-10 · 0001552781-23-000006