SEC Comment Letter for A. M. Castle & Co. (CIK 0000018172) — Jun 9, 2005
A. M. Castle & Co. (CIK 0000018172)
Date: June 9, 2005 · CIK: 0000018172 · Accession: 0000000000-05-028870
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June 9, 2005
Via U.S. Mail and Facsimile to (847) 455-6930
Mr. Lawrence A. Boik
Chief Financial Officer
A. M. Castle & Co.
3400 North Wolf Road
Franklin Park, IL 60131
Re: A. M. Castle & Co.
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 16, 2005
File No. 1-5415
Dear Mr. Boik:
We have reviewed your filing and have the following
comments. We
have limited our review to those issues we have addressed in our
comments.
Where indicated, we think you should revise your document in
response to
these comments. If you disagree, we will consider your
explanation as to
why our comment is inapplicable or a revision is unnecessary.
Please be
as detailed as necessary in your explanation. After reviewing
this
information, we may raise additional comments.
Please understand that the purpose of our review process is
to assist
you in your compliance with the applicable disclosure requirements
and to
enhance the overall disclosure in your filing. We look forward to
working
with you in these respects. We welcome any questions you may have
about
our comments or any other aspect of our review. Feel free to call
us at
the telephone numbers listed at the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2004
Balance Sheet, page 19
1. Please revise your inventory presentation to separately report
the
value of inventory consigned to others at each balance sheet date.
See
Question 2 of SAB Topic 13-A-2.
2. Include in Management`s Discussion and Analysis, a more
detailed
analysis of the revenue recognized in each period from sales of
consigned
inventory.
Closing Comments
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us with
a response. You may wish to provide us with marked copies of the
amendment to expedite our review. Please furnish a cover letter
with your
amendment that keys your responses to our comments and provides
any
requested information. Detailed cover letters greatly facilitate
our
review. Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filing to be certain that the filing
includes all
information required under the Securities Exchange Act of 1934 and
that
they have provided all information investors require for an
informed
investment decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have
made.
In connection with responding to our comments, please
provide, in
writing, a 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 comments as a defense in any
proceeding
initiated by the Commission or any person under the federal
securities
laws of the United States.
In addition, please be advised that the Division of
Enforcement has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our
comments on your filing.
You may contact Gabrielle Malits, Staff Accountant, at (202)
551-3702
if you have questions regarding comments on the financial
statements and
related matters. Please contact me at (202) 551-3683 with any
other
questions.
Sincerely,
Jill Davis
Branch Chief
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Mr. Lawrence A. Boik
A. M. Castle & Co.
June 9, 2005
page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
MAIL STOP 04-05
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