SEC Comment Letter for DANA INC (DAN) (CIK 0000026780) (DAN) — Dec 27, 2016
DANA INC (DAN) (CIK 0000026780)
Date: Dec. 27, 2016 · CIK: 0000026780 · Accession: 0000000000-16-106507
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 December 27, 2016 Jonathan M. Collins Chief Financial Officer Dana Incorporated 3939 Technology Drive Maumee, Ohio 43537
Re: Dana Incorporated Form 10-K for the Year Ended December 31, 2015 Form 10 -Q for the Quarter Ended September 30, 2016 File No. 00 1-01063
Dear Mr. Collins :
We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and ci rcumstances , please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -Q for the Quarter Ended September 30, 2016
Management’s Discussion and Analysis of Financial Condi tion and Results of Operations
Liquidity, page 43
1. We note your presentation of the non -GAAP measure “operating liquidity.” Please revise to include a statement disclosing the reasons why management believes that presentation of th is non-GAAP financial m easure provides useful information to investors regarding the registrant's financial condition and results of operations and a statement disclosing the additional purposes for which the management uses the non - GAAP financial measure in accordance with Item 10(e)(1)(i) of Regulation S -K. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Jonathan M. Collins Dana Incorporated December 2 7, 2016 Page 2
You may contact Effie Simpson at 202 -551-3346 or Heather Clark at 202 -551-3624 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
Show Raw Text
Mail Stop 3561 December 27, 2016 Jonathan M. Collins Chief Financial Officer Dana Incorporated 3939 Technology Drive Maumee, Ohio 43537 Re: Dana Incorporated Form 10-K for the Year Ended December 31, 2015 Form 10 -Q for the Quarter Ended September 30, 2016 File No. 00 1-01063 Dear Mr. Collins : We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and ci rcumstances , please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -Q for the Quarter Ended September 30, 2016 Management’s Discussion and Analysis of Financial Condi tion and Results of Operations Liquidity, page 43 1. We note your presentation of the non -GAAP measure “operating liquidity.” Please revise to include a statement disclosing the reasons why management believes that presentation of th is non-GAAP financial m easure provides useful information to investors regarding the registrant's financial condition and results of operations and a statement disclosing the additional purposes for which the management uses the non - GAAP financial measure in accordance with Item 10(e)(1)(i) of Regulation S -K. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Jonathan M. Collins Dana Incorporated December 2 7, 2016 Page 2 You may contact Effie Simpson at 202 -551-3346 or Heather Clark at 202 -551-3624 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3379 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure