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Corporate Office:
25 St. James’s Street
London, SW1A 1HA United Kingdom
September 18, 2020
Via EDGAR
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: | Christine Dietz, Senior Staff Accountant |
Eiko Yaoita Pyles, Staff Accountant |
Re: | CNH Industrial N.V. |
Form 20-F for the Fiscal Year Ended December 31, 2019 |
Filed March 3, 2020 |
File No. 001-36085 |
Ladies and Gentlemen:
Set forth below is the response of CNH Industrial N.V. (the “Company”, “CNH Industrial”, “we” or “our”) to the comment of the Staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Staff”) set forth in its letter dated September 4, 2020 regarding its review of CNH Industrial’s filing noted above and our response letter submitted on August 24, 2020. For your convenience, we have restated in bold font the Staff’s comment followed by our response.
Form 20-F for the Fiscal Year Ended December 31, 2019
Notes to Consolidated Financial Statements
Note 22. Supplemental Information, page F-65
1. | Comment: We note your response to prior comment 7. Please revise in future filings to remove the presentation of the Financial Services segment using the equity method of accounting. Refer to Question 100.04 of the Non-GAAP Compliance and Disclosure Interpretations. |
Page 2
Response:
In response to the Staff’s comment, in future filings, we confirm that we will remove the Supplemental Information contained in Note 22 which includes removing the presentation of the Financial Services segment using the equity method of accounting.
Thank you again for your time. Please feel free to contact me at +39 335 828 3371 or by email (oddone.incisa@cnhind.com) or Scott D. Miller of Sullivan & Cromwell LLP at (212) 558-3109 or by email (millersc@sullcrom.com) with any questions you may have.
Sincerely, |
/s/ Oddone Incisa |
Oddone Incisa |
Chief Financial Officer |
CNH Industrial N.V. |
cc: | Roberto Russo |
Monica Ciceri
Michael P. Going
(CNH Industrial N.V.)
Scott Miller
(Sullivan & Cromwell LLP)