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United States securities and exchange commission logo
April 30, 2024
Sunil Mathew
Senior Vice President and Chief Financial Officer
Occidental Petroleum Corporation
5 Greenway Plaza, Suite 110
Houston, Texas 77046
Re: Occidental
Petroleum Corporation
Form 10-K for
Fiscal Year Ended December 31, 2023
File No. 001-09210
Dear Sunil Mathew:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Financial Statements and Supplementary Data
Note 16 - Geographic Areas and Industry Segments, page 112
1. We note from your
disclosure on page 3 that the midstream and marketing segment
includes your
low-carbon ventures businesses ( OLCV ) and that these businesses seek
not only to leverage
carbon management in your operations but also to strategically
partner with other
industries to help reduce their emissions. We further note disclosure
on page 44 that OLCV
provides services to third parties to facilitate the implementation of
their CCUS projects and
that OLCV is fostering emerging technologies, including DAC
and low-carbon power
sources, and other business models with the potential to position
Occidental as a leader
in the production of low-carbon energy and products. Please
explain in sufficient
detail how you evaluated whether OLCV is considered a separate
operating segment under
the guidance of FASB ASC 280-10-50. As part of your response,
please address the
following:
If you do not
consider OLCV to be a separate operating segment, provide an analysis
Sunil Mathew
Occidental Petroleum Corporation
April 30, 2024
Page 2
to support your position in accordance with FASB ASC paragraphs
280-10-50-1
through 50-9.
If you do consider OLCV to be a separate operating segment that
you aggregate for
reporting purposes into the midstream and marketing segment,
provide an analysis to
support your position that OLCV meets the aggregation criteria in
FASB ASC
paragraph 280-10-50-11.
Supplemental Oil and Gas Information
Oil and Gas Reserves, page 114
2. Tell us the quantity of reported reserves that are attributable to
investments that are
accounted for by the equity method and where they are reflected in
your supplemental oil
and gas reserve disclosure. Additionally, explain to us how your
presentation takes into
consideration the guidance in FASB ASC paragraph 932-235-50-8(c).
Results of Operations, page 121
3. Footnote (b) to your presentation of results of operations indicates,
in part, that revenues
include income from equity investments. Explain to us how this
presentation takes into
consideration the guidance of FASB ASC paragraph 932-235-50-28.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Jennifer O'Brien at 202-551-3721 or Shannon Buskirk at
202-551-3717 if
you have questions regarding comments on the financial statements and related
matters. You
may contact Sandra Wall at 202-551-4727 or Brad Skinner at 202-551-3489 with
questions
about engineering comments.
FirstName LastNameSunil Mathew Sincerely,
Comapany NameOccidental Petroleum Corporation
Division of
Corporation Finance
April 30, 2024 Page 2 Office of
Energy & Transportation
FirstName LastName