SRSEC Reporting Desk

COSTCO WHOLESALE CORP /NEW (COST)

CIK 909832 · EDGAR correspondence

DateCompanyTypeOutcomeIssues
2026-03-26COSTCO WHOLESALE CORP /NEW (COST)SEC staff letterReview completed (no further comments)
2026-03-23COSTCO WHOLESALE CORP /NEW (COST)Company responseAgreed to reviseSegment Reporting (ASC 280)MD&A: Results & Known TrendsLiquidity & Capital ResourcesStatement of Cash Flows (ASC 230)
2026-03-04COSTCO WHOLESALE CORP /NEW (COST)SEC staff letter2 staff comment(s) issuedSegment Reporting (ASC 280)MD&A: Results & Known TrendsLiquidity & Capital ResourcesStatement of Cash Flows (ASC 230)

Comments & responses

2026-03-04 · Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 · Comment 1 · Cash Flows from Operating Activities, page 29 Agreed to revise
Staff comment: Please provide a period to period comparative analysis and discussion of changes in cash flows from operating activities, including changes in working capital components, in your annual and interim period reports. In doing so, explain the underlying business reasons and implications of material changes between periods to provide investors with an understanding of variability and potential trends in cash flows. Ensure your discussion and analysis is not merely a recitation of changes evident from the consolidated statements of cash flows. Refer to Item 303(a) and (b) of Regulation S-K and SEC Release No. 33-8350. letter →
Company response: We respectfully acknowledge the Staff’s comments and will expand our disclosures to include a comparative analysis and discussion of changes in cash flows from operating activities in future filings. The following is an example of the future disclosure: Cash Flows from Operating Activities Our cash flow provided by operations is primarily from net sales and membership fees. Cash flow used in operations generally consists of payments to merchandise suppliers, warehouse operating costs, including wages and employee benefits, utilities, credit and debit card processing fees, and operating leases. Cash used in operations also includes payments for income taxes. Changes in our net investment in… response letter →
MD&A: Results & Known TrendsLiquidity & Capital ResourcesStatement of Cash Flows (ASC 230)
2026-03-04 · Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 · Comment 2 · Note 11 - Segment Reporting, page 62 Agreed to revise
Staff comment: You disclose the CODM utilizes operating income in evaluating performance and allocating resources but not how the measure is used for these purposes. Refer to ASC 280-10-50-29(f) and ASC 280-10-55-47(bb). Please revise as appropriate. letter →
Company response: We will revise our disclosure in our future filings to include how the CODM utilizes operating income as described below: The CODM uses the metrics outlined in the table below, along with internal management reports, to evaluate performance, monitor actual results versus budget and prior year results, and make strategic and operational resource allocation decisions. Please contact me response letter →
Segment Reporting (ASC 280)

Templates & resources

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