BERKSHIRE HATHAWAY INC.
3555 FARNAM STREET
SUITE 1440
OMAHA, NEBRASKA 68131
TELEPHONE (402) 346-1400
FAX (402) 346-3375
April 12, 2010
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: | Berkshire Hathaway Inc. |
Dear Mr. Rosenberg:
The purpose of this letter is to respond to your letter dated March 29, 2010 concerning Berkshires accounting for repurchase agreements, securities lending transactions and other transactions involving the transfer of financial assets with an obligation to repurchase the transferred assets. Our specific responses to your inquiries are as follows:
During the three year period ending December 31, 2009, we did not enter into any repurchase agreements involving financial assets which were accounted for as sales in our consolidated financial statements.
As of December 31, 2006, certain Berkshire subsidiaries had entered into a limited amount of repurchase agreements that were being accounted for as financing transactions. As of December 31, 2006, the balance of securities sold under these agreements to repurchase was approximately $600 million and was reflected as a component of other liabilities in our consolidated financial statements. These liabilities were repaid in full during the third quarter of 2007.
During the three year period ending December 31, 2009, we did not engage in any securities lending transactions that were accounted for as sales or other transactions involving the transfer of financial assets with an obligation to repurchase the transferred assets that were accounted for as sales pursuant to the guidance in ASC 860 then in effect.
Finally, we did not offset financial assets and liabilities in the balance sheet when the right of offset did not exist.
Please contact me if you have any questions at (402) 978-5423. Thank you.
Very truly yours,
BERKSHIRE HATHAWAY INC. | ||||
/s/ Marc D. Hamburg |
By Marc D. Hamburg |
Senior Vice President and Chief Financial Officer |
CC: | Daniel J. Jaksich, Vice President and Controller |
Mr. Gus Rodriguez, Accounting Branch Chief |