SEC Company Response from SUNation Energy, (SUNE) — Jan 6, 2014
SUNation Energy, Inc.
Date: Jan. 6, 2014 · CIK: 0000022701 · Accession: 0000897101-14-000033
AI Filing Summary & Sentiment
File numbers found in text: 001-31588
Letter
Securities and Exchange Commission Form 10-K for Fiscal Year Ended December 31, 2012 Filed March 15, 2013 File No. 001-31588
Re: Communications Systems, Inc.
Dear Mr. Spirgel
This is response to your letter of December 19, 2013, and the following Commission staff comment:
Form 10-K for the Fiscal Year Ended December 31, 2012
Part III Information Incorporated by Reference to Definitive Proxy Statement filed on April 10, 2013
Compensation Discussion and Analysis, page 13
1. On pages 16 and 17 you discuss objective performance measures applicable to your Annual Bonus Plan and Long Term Incentive Compensation. Please disclose these measures and provide additional disclosure to clarify how the actual amounts paid out for 2012 were determined
Response
Based on my conversation with Greg Dundas of the Commission staff, Communications Systems, Inc. (the “Company”) hereby advises the staff as follows:
In its Form 10-K and Proxy Statement for the fiscal year ended December 31, 2013, the Company will disclose the target objective performance measures for our Annual Bonus Plan and Long-Term Incentive Compensation for the year just ended.
The Proxy Statement for the Company’s 2013 Annual Meeting of Shareholders disclosed how the Company calculated the amounts paid. We will continue that disclosure. There were no Long Term Incentive Awards in 2012 because no plan ended in 2012. There were Stock Options awarded for the plan that began in 2012 based on 30 % of the Total Target LTI Opportunity.
Representations
The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the filing.
We understand that 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.
We understand that CSI may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under federal securities laws of the United States.
Sincerely
Edwin C. Freeman
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CORRESP
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January 6, 2014
SEC Correspondence
Larry Spirgel
Assistant Director
Securities and Exchange Commission
Washington, D.C. 20549
Re:
Communications Systems, Inc.
Form 10-K for Fiscal Year Ended December 31, 2012
Filed March 15, 2013
File No. 001-31588
Dear Mr. Spirgel
This is response to your letter of December
19, 2013, and the following Commission staff comment:
Form 10-K for the Fiscal Year Ended December 31, 2012
Part III Information Incorporated by Reference to Definitive
Proxy Statement filed on April 10, 2013
Compensation Discussion and Analysis, page 13
1. On pages 16 and 17 you discuss objective
performance measures applicable to your Annual Bonus Plan and Long Term Incentive Compensation. Please disclose these measures
and provide additional disclosure to clarify how the actual amounts paid out for 2012 were determined
Response
Based on my conversation with Greg Dundas
of the Commission staff, Communications Systems, Inc. (the “Company”) hereby advises the staff as follows:
In its Form 10-K and Proxy Statement
for the fiscal year ended December 31, 2013, the Company will disclose the target objective performance measures for our Annual
Bonus Plan and Long-Term Incentive Compensation for the year just ended.
The Proxy Statement for the Company’s
2013 Annual Meeting of Shareholders disclosed how the Company calculated the amounts paid. We will continue that disclosure. There
were no Long Term Incentive Awards in 2012 because no plan ended in 2012. There were Stock Options awarded for the plan that began
in 2012 based on 30 % of the Total Target LTI Opportunity.
Representations
The Company acknowledges that it is responsible
for the adequacy and accuracy of the disclosure in the filing.
We understand that 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.
We understand that CSI may not assert
staff comments as a defense in any proceeding initiated by the Commission or any person under federal securities laws of the United
States.
Sincerely
Edwin C. Freeman
Chief Financial Officer
Communications Systems, Inc.