SEC Comment Letter for AZZ INC (AZZ) (CIK 0000008947) (AZZ) — Oct 2, 2014
AZZ INC (AZZ) (CIK 0000008947)
Date: Oct. 2, 2014 · CIK: 0000008947 · Accession: 0000000000-14-049555
AI Filing Summary & Sentiment
Reasoning
Letter
October 2, 2014 Via E -mail Mr. Paul W. Fehlman Chief Financial Officer AZZ incorporated One Museum Place, Suite 500 3100 West Seventh Street Fort Worth, Texas 76107
Re: AZZ incorporated Form 10-K for the Year Ended February 28, 2014 Filed April 28, 2014 File No. 1-12777
Dear Mr. Fehlman :
We have reviewed your filing and have the following comment. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. P lease comply with the comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended February 28, 2014
Notes to Consolidated F inancial Statements
11. Operating segment, page 50
1. We note from the fourth paragraphs of pages 4 and 5 that international sales provided approximately 18% of your revenues during the year ended February 28, 2014. We also note from your earnings call of J une 27, 2014 that you expect international revenues to continue to increase as a percentage of your total revenues over time. Please disclose the geographic information required by ASC 280 -10-50-41.
Mr. Paul W. Fehlman AZZ incorporated October 2, 2014 Page 2
We urge all persons who are responsible for the accura cy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts r elating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff c omments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Christie Wong , Staff Accountant, at (202) 551 -3684 or Joseph M. Kempf , Senior Staff Accountant , at (202) 551 -3352 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage, for
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October 2, 2014 Via E -mail Mr. Paul W. Fehlman Chief Financial Officer AZZ incorporated One Museum Place, Suite 500 3100 West Seventh Street Fort Worth, Texas 76107 Re: AZZ incorporated Form 10-K for the Year Ended February 28, 2014 Filed April 28, 2014 File No. 1-12777 Dear Mr. Fehlman : We have reviewed your filing and have the following comment. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. P lease comply with the comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended February 28, 2014 Notes to Consolidated F inancial Statements 11. Operating segment, page 50 1. We note from the fourth paragraphs of pages 4 and 5 that international sales provided approximately 18% of your revenues during the year ended February 28, 2014. We also note from your earnings call of J une 27, 2014 that you expect international revenues to continue to increase as a percentage of your total revenues over time. Please disclose the geographic information required by ASC 280 -10-50-41. Mr. Paul W. Fehlman AZZ incorporated October 2, 2014 Page 2 We urge all persons who are responsible for the accura cy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts r elating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff c omments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Christie Wong , Staff Accountant, at (202) 551 -3684 or Joseph M. Kempf , Senior Staff Accountant , at (202) 551 -3352 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spir gel Assistant Director