We respectfully note for the Staff that all of the amounts needed for the reconciliations
required by ASC 280-10-50-30 are provided in our quantitative disclosure, and all significant reconciling items are separately
identified and described in accordance with ASC 280-10-50-31. We believe our current presentation facilitates the inclusion of a
Total Automotive metric in a manner that is easily understood by a user of our financial statements. Refer to our response to Comment No. 3 as to why we present a Total Automotive subtotal. We also believe reconciling to a total consolidated
Earnings (loss) before interest and taxes-adjusted amount aligns with the principles in Topic 280 as this metric is regularly provided to and used by our chief operating decision-maker to make resource allocation decisions. This metric is also a
primary metric contained in our materials provided to investors and analysts. We believe our current quantitative disclosure not only presents how our reportable segments information relates to the consolidated total in an easily understood fashion,
but also facilities a user’s understanding of other financial metrics that are communicated to interested parties.
In response to
the Staff’s comment, we propose adding a footnote to our table in future filings that discloses the total reportable segment amounts for Net sales and revenue, Earnings (loss) before interest and taxes–adjusted, and Total assets as
opposed to revising our current tabular format. We would include totals for other reportable segments’ amounts being disclosed (e.g., Expenditures for property, Depreciation and amortization, etc.) if the reconciling amounts are other than
minor. The inclusion in future filings of the totals in a footnote would clarify the amounts needed for the reconciliations required by ASC
280-10-50-30. Refer to an illustrative example in the Exhibit attached hereto.
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We also note that the “Corporate” column includes amounts, such as net sales and revenue,
segment expenses and other items, adjustments, and earnings (loss) before interest and taxes—adjusted. ASC 280-10-50-15
requires information about other business activities and operating segments that are not reportable to be combined and disclosed in an all other category separate from other reconciling items in the reconciliations required by ASC 280-10-50-30 through 50-31. Please revise your disclosures accordingly. Please provide us with
your proposed revised disclosure. See also ASC 280-10-55-48. |
We disclose in our Note 23 that Corporate includes certain centrally recorded income and costs, such as corporate expenditures and certain
revenues and expenses that are not included in another reportable segment.1 In accordance with paragraph 280-10-50-15, Corporate represents an “all other” category consisting of other business activities primarily associated with our automotive operations. Corporate does not include
eliminations and other reconciling items needed to derive our consolidated results. As such, the tabular presentation in Note 23 does, in accordance with paragraph 280-10-15-25, present “All Other” activities separate from other reconciling items needed to derive our consolidated results. The Net sales and revenue, expenses, Adjustments, and Earnings
(loss) before interest and taxes–adjusted amounts are presented in Corporate to facilitate the reconciliation of our reportable segment amounts to consolidated amounts and, as noted in the response to Comment No. 1, to permit a user to
better understand the components of our consolidated Earnings (loss) before interest and taxes–adjusted financial metric. The amounts presented in Corporate for Total assets, Expenditures for property, Depreciation and amortization and
Impairments (if applicable) also facilitate a reconciliation to our consolidated amounts. Please refer to our proposal to add an additional footnote to our table in future filings in our response to Comment No. 1.
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See Note 23. Segment Reporting, in GM’s 2024 Form 10-K at page
100: “Our automotive interest income and interest expense, legacy costs from the Opel/Vauxhall Business (primarily pension costs), corporate expenditures and certain revenues and expenses that are not part of a reportable segment are
recorded centrally in Corporate. Corporate assets primarily consist of cash and cash equivalents, marketable debt securities and intersegment balances. All intersegment balances and transactions have been eliminated in consolidation.”
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