SecProbe.io

July 29, 2019
Carol B. Yancey
Chief Financial Officer
Genuine Parts Company
2999 Wildwood Parkway
Atlanta, Georgia 30339
Re:Genuine Parts Company
Form 10-K for the Year Ended December 31, 2018
Filed February 25, 2019
File No. 001-05690
Dear Ms. Yancey:
            We have reviewed your filing and 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 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures, page 21
1.We note that your current disclosure about the usefulness of your non-GAAP measures
indicates that you believe that the presentation of adjusted net income and adjusted net
income per common share is indicative of the company's core operations.  Please revise to
provide a more substantive discussion of how your non-GAAP measures are useful to
investors.  Refer to Item 10(e)(1)(i)(C) of Regulation S-K.  Earnings releases on Forms 8-
K should be similarly revised.
Item 9A. Controls and Procedures
Management’s conclusion regarding the effectiveness of disclosure controls and procedures,
page 27
2.We note in the first paragraph of this section that you discuss management's evaluation of

 FirstName LastNameCarol B. Yancey
 Comapany NameGenuine Parts Company
 July 29, 2019 Page 2
 FirstName LastName
Carol B. Yancey
Genuine Parts Company
July 29, 2019
Page 2
the the effectiveness of  disclosure controls and procedures, however, the conclusion
references your internal control over financial reporting instead of disclosing the
conclusion of the effectiveness of your disclosure controls and procedures.  Please amend
the filing to disclose the conclusion of your principal executive and principal financial
officers regarding the effectiveness of the company's disclosure controls and procedures
as of the end of the period covered by the report.  In doing so, please ensure that your
certifications reference the Form 10-K/A. and are currently dated.  Refer to Item 307 of
Regulation S-K.  Your Form 10-Qs for the quarters ended March 31, 2019 and June 30,
2019 should be similarly amended.
Financial Statements
Notes to Consolidated Financial Statements
2. Revenue Recognition, page F-13
3.Please disclose the nature and amount of any contract assets and contract liabilities along
with the applicable disclosure requirements in ASC 606-10-50-8 through 10.
            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.
            You may contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure