<SEC-DOCUMENT>0000088121-15-000010.txt : 20151028
<SEC-HEADER>0000088121-15-000010.hdr.sgml : 20151028
<ACCEPTANCE-DATETIME>20150831100041
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000088121-15-000010
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20150831

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			SEABOARD CORP /DE/
		CENTRAL INDEX KEY:			0000088121
		STANDARD INDUSTRIAL CLASSIFICATION:	 [6221]
		IRS NUMBER:				042260388
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		9000 W. 67TH STREET
		CITY:			SHAWNEE MISSION
		STATE:			KS
		ZIP:			66202
		BUSINESS PHONE:		9136768800

	MAIL ADDRESS:	
		STREET 1:		9000 W. 67TH STREET
		CITY:			SHAWNEE MISSION
		STATE:			KS
		ZIP:			66202

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	SEABOARD ALLIED MILLING CORP
		DATE OF NAME CHANGE:	19820328

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	HATHAWAY BAKERIES INC
		DATE OF NAME CHANGE:	19710315
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                           SEABOARD
                          CORPORATION



August 31, 2015


Kristi Marrone
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC  20549


RE:  Seaboard Corporation
     Form 10-K for the fiscal year ended December 31, 2014
     Response dated August 3, 2015
     File No. 001-03390


Dear Ms. Marrone:

We  are writing in response to your letter dated August 21, 2015,
with  respect  to the above-referenced report filed  by  Seaboard
Corporation   ("Seaboard"  or  the  "Company").    Our   numbered
responses to your comments correspond to the numbered comments in
your letter.

                   COMMENTS AND OUR RESPONSES

Form 10-K for the fiscal year ended December 31, 2014

Notes to Consolidated Financial Statements, page 32

Comment 1: We  note  your  response to comment 1 that  the  large
           majority  of  your current trade receivables  and  due
           from affiliates were not past due. Please tell us  the
           credit  terms and the specific dollar amount  of  past
           due  balances of your foreign receivables. Tell us how
           you evaluated the significance of this information  to
           an  investor's financial assessment of the company and
           a comparison of the company to its competitors.

Response:  Although  our subsidiaries and affiliates do not  have
           consistent  standard  credit  terms,  most   generally
           range  between  30  and  60 days.  We  do  have  trade
           receivable  accounts that age from time to  time,  but
           we  generally do not focus on accounts until they have
           aged   greater  than  90  days,  unless   a   specific
           collectability  concern  has been  identified.  As  of
           December  31,  2014  approximately $33.7  million,  or
           6.4%  of  our  total $530.0 million trade

<PAGE>

           receivables and due from  affiliates were greater than
           90 days  past  due,  net of  reserves, including $15.3
           million, or 45.4% of the greater than 90 days balance,
           related to the Power segment and the Brazilian   flour
           production   business.  Each  of  our  other   foreign
           entities having past due receivables greater  than  90
           days  accounted  for less than 1% of the  total  trade
           receivables  and  due  from  affiliates  and  did  not
           aggregate to any heightened level of collection risk.

           Our  foreign receivable risk is distributed over  many
           different companies, industries and countries  and  we
           have  not  historically experienced greater write-offs
           of  foreign  receivables, except for those receivables
           we  have  specifically discussed in  our  filings.  In
           addition,  due  to  the disaggregated  nature  of  our
           foreign receivables and certain country locations,  we
           are  unable  to benchmark collection risk to  specific
           competitors.  The risk we reference  in  the  Critical
           Accounting   Estimates  and  in   Note   12,   Segment
           Information  of  our  annual  report  was   meant   to
           primarily   relate  to  our  Power   Segment   foreign
           receivables in the Dominican Republic, which at  times
           has  historically  been dependent  on  the  government
           obtaining  external  financing and  specific  risk  in
           certain  countries  that  are experiencing  distressed
           economic  conditions  and that have  more  significant
           receivable  balances, such as Brazil currently.  While
           we   believe   certain  of  our  foreign   receivables
           generally  represent  more of a collection  risk  than
           domestic  receivables,  this  was  not  meant  to   be
           interpreted  that  all  our  foreign  receivables  are
           riskier  than  our  domestic  receivables.  In  future
           Exchange   Act  periodic  reports,  we   will   modify
           disclosure  to  specifically reference  which  foreign
           trade  receivables and due from affiliates receivables
           are  at  a  heightened  risk and  to  the  extent  its
           material    and    meaningful    we    will    include
           quantifications    to    enhance     an     investor's
           understanding of the risk.


Form 10-Q for the quarterly period ended July 4, 2015

Note 9 - Segment Information, page 14

Comment 2: We  note  your response to comment 2 relating  to  the
           $34.6   million  note  receivable  from   the   bakery
           business  in DRC. We note on page 15 of the referenced
           Form  10-Q  that no payment was received in  June  and
           you  agreed  to  review future payment  terms.  Please
           tell  us  with sufficient specificity the  assumptions
           used   in  estimating  future  cash  flows  for   this
           business   and   how   you   determined   that   those
           assumptions   were  reasonable  given  the   continued
           operating  losses and other challenges faced  by  this
           business and the default on the first payment  due  in
           June 2015.

Response:  The  bakery  business  in the Democratic  Republic  of
           Congo   was  a  greenfield  construction,  originating
           during  the fourth quarter of 2012. The initial start-
           up  phase  has  been  extended as challenges  such  as
           securing  a  consistent fuel and  electricity  source,
           the  development  of  a country-specific  distribution
           model,  and

<PAGE> 2

           resolving technical  and  quality  issues  have  taken
           longer   than   originally   projected.   Cash    flow
           assumptions were revised at the end of 2014 to reflect
           the  extended  nature  of  the  start-up  period    as
           compared  to  the original forecast which resulted  in
           the write-off of the investment. The forecast used  at
           December  31, 2014 estimated continued losses  in  the
           near  term  and that once the operational  and  market
           issues    (credible   and   sustainable   distribution
           channels,   steady  stream  of  power  and  consistent
           quality  of  production) were resolved,  the  business
           plan,  which projects increasing production and market
           share,  would  be achieved resulting in positive  cash
           flows and a sustained level of profitability.

           As  of  the  second quarter of 2015, the forecast  was
           revised  to reflect the actual improvements in  volume
           and  EBITDA  achieved during the first six  months  of
           2015   as   compared  to  our  2014  year-end  revised
           projections.   Specific  improvements   included   new
           products  being  developed and  sold,  improved  shelf
           life  and quality, and the completion of new logistics
           design  which  is  expected  to  improve  volumes  and
           profitability.

           We  used a probability weighting of the different cash
           flow  scenarios,  but did not assume  that  the  other
           equity   partner's   guarantee   of   the   debt   was
           collectable,  although it may be.  In  evaluating  the
           future  cash  flows  estimates,  we  used  a  discount
           factor  based  on  the  effective  rate  on  the  note
           receivable.  In addition, we used commission,  volume,
           pricing  and margins assumptions consistent with  what
           is  currently being achieved and took into account the
           positive  impact of improved shelf life  and  quality.
           Our  forecasts  reflect that when all operational  and
           market   issues   are  substantially   resolved,   the
           business  will deliver a more reliable and  consistent
           product  and  achieve increased volume and  additional
           market share.  Although our equity investment in  this
           business  has  been  written-off, management  believes
           the  business plan is achievable and that the business
           will  generate  positive  cash  flows  sufficient   to
           recover the note receivable.

           We  compare  our  assumptions to weekly  snapshots  of
           bread  production that provides sales  volumes,  price
           per  product  sold,  variable  costs  and  consumption
           rates  per sack of flour, kilograms of yeast and  salt
           and  liter  of  fuel to monitor the  progress  of  the
           specific   improvements  and  as   a   comparison   to
           forecast.  Additionally,  although  no  agreement  has
           been  reached,  we  believe  the  payment  terms   and
           maturity  of the bakery's debt to us will be  extended
           to  better  match the projected future cash  flows  of
           the business.

Comment 3: We  note your response to comment 3. We note that your
           investment  in  and advances and note receivable  from
           the  flour  production business in  Brazil  have  been
           written  down to zero. We further note on page  15  of
           the   referenced  Form  10-Q  that  you  had  a  gross
           receivable   due  from  affiliate  related   to   this
           business  resulting from sales of grain  and  supplies
           of  $16.5  million  as  of  July  4,  2015  which  you
           reserved   $3   million  based  on  an   analysis   of
           collectability  and

<PAGE> 3

           working capital.  Please  tell  us    with  sufficient
           specificity  how  you  came  to  the  conclusion  that
           no additional allowance  for  losses  was necessary as
           of July 4, 2015.

Response:  In  evaluating the collectability of the $16.5 million
           trade  receivable,  Seaboard  considered  the  working
           capital  of the business, which is one of the measures
           that  Seaboard  typically  uses  as  an  indicator  of
           impairment,    along    with   our    knowledge    and
           understanding  of  the  operational  performance   and
           capabilities  of the business. Historically,  negative
           working  capital  has been a good early  indicator  of
           collectability  concerns at Seaboard's nonconsolidated
           affiliates,   although  it  does   not   always   mean
           impairment because it does not reflect the  cash  flow
           generating capability of the fixed assets. As  of  the
           end  of  the  second quarter of 2015, the company  had
           negative  working capital. To evaluate the  amount  of
           any  allowance for bad debt that should  be  recorded,
           we  considered  a probability weighting of  collection
           scenarios  that  assumed third-party bank  debt  would
           first  be  paid back and then evaluated the  remaining
           cash   available   to  recover  the  receivable.   The
           critical  assumptions used in the  various  collection
           scenarios were the completion of the refurbishment  of
           an   operating   plant  during  the   third   quarter,
           improvements  to  the shelf life and  quality  of  the
           flour  resulting  from operational changes  made  over
           the  last  year and the expiration of a  mill  tolling
           agreement  during  the  third  quarter  of  2015.  Our
           analysis  indicated that a reserve of $3  million  was
           required.

           Management  notes  certain positive developments  were
           included  in the analysis of collectability  including
           the  improvement of yield and the third quarter ending
           of  a  toll  milling arrangement that  has  previously
           constrained  the  company's ability  to  make  certain
           improvements.    Additional   positive    developments
           expected  but  not  specifically  included   in   this
           analysis were the impact of a new production  line  at
           our  primary  milling facility, successful replacement
           of   the   managing  director  and  certain   overhead
           reductions expected during the second half of 2015.

We  hope that the above has been of assistance to you and that it
is  fully responsive to your comments.  If you have any questions
or   require   any  further  information,  please  call   me   at
(913)  676-8833 or Michael Trollinger, Vice President,  Corporate
Controller and Chief Accounting Officer at (913) 676-8735.

Very truly yours,

SEABOARD CORPORATION


/s/ Robert L. Steer
Robert L. Steer
Executive Vice President and
Chief Financial Officer

<PAGE> 4
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
