SEC Comment Letter 0000000000-24-002953 to COMMERCIAL METALS Co (CMC) (CIK 0000022444) (CMC)
COMMERCIAL METALS Co (CMC) (CIK 0000022444)
Date: March 19, 2024 · CIK: 0000022444 · Accession: 0000000000-24-002953
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-04304
Referenced dates: February 29, 2024
Letter
United States securities and exchange commission logo March 19, 2024 Paul J. Lawrence Senior Vice President and Chief Financial Officer Commercial Metals Company 6565 N. MacArthur Blvd. Irving, TX 75039 Re:Commercial Metals Company Form 8-K Filed January 8, 2024 Response dated March 14, 2024 File No. 001-04304 Dear Paul J. Lawrence: We have reviewed your March 14, 2024 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our February 29, 2024 letter. Form 8-K Filed January 8, 2024 Exhibit No. 99.1, page 12 1.Please refer to prior comment 2 of our letter dated February 29, 2024. Based on your March 14, 2024 response, mill operational commissioning costs appear to be normal operating expenses necessary to operate your business. As such, the adjustment to your non-GAAP financial measures for these costs appears to be inconsistent with Question 100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Please revise your presentations in future filings to remove this adjustment from your non-GAAP financial measures.
FirstName LastNamePaul J. Lawrence Comapany NameCommercial Metals Company March 19, 2024 Page 2 FirstName LastName Paul J. Lawrence Commercial Metals Company March 19, 2024 Page 2 Please contact Jeffrey Gordon at 202-551-3866 or Jean Yu at 202-551-3305 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
United States securities and exchange commission logo
March 19, 2024
Paul J. Lawrence
Senior Vice President and Chief Financial Officer
Commercial Metals Company
6565 N. MacArthur Blvd.
Irving, TX 75039
Re:Commercial Metals Company
Form 8-K Filed January 8, 2024
Response dated March 14, 2024
File No. 001-04304
Dear Paul J. Lawrence:
We have reviewed your March 14, 2024 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our February 29,
2024 letter.
Form 8-K Filed January 8, 2024
Exhibit No. 99.1, page 12
1.Please refer to prior comment 2 of our letter dated February 29, 2024. Based on your
March 14, 2024 response, mill operational commissioning costs appear to be normal
operating expenses necessary to operate your business. As such, the adjustment to your
non-GAAP financial measures for these costs appears to be inconsistent with Question
100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures. Please revise your presentations in future filings to remove this adjustment
from your non-GAAP financial measures.
FirstName LastNamePaul J. Lawrence
Comapany NameCommercial Metals Company
March 19, 2024 Page 2
FirstName LastName
Paul J. Lawrence
Commercial Metals Company
March 19, 2024
Page 2
Please contact Jeffrey Gordon at 202-551-3866 or Jean Yu at 202-551-3305 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing