SEC Comment Letter 0000000000-23-008351 to GENUINE PARTS CO (GPC)
GENUINE PARTS CO
Date: Aug. 3, 2023 · CIK: 0000040987 · Accession: 0000000000-23-008351
AI Filing Summary & Sentiment
File numbers found in text: 001-05690
Letter
United States securities and exchange commission logo August 3, 2023 Bert Nappier Executive Vice President and Chief Financial Officer Genuine Parts Company 2999 Wildwood Parkway Atlanta, GA 30339 Re:Genuine Parts Company Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 23, 2023 File No. 001-05690 Dear Bert Nappier: 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 Fiscal Year Ended December 31, 2022 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Consolidated Results of Operations, page 19 1.You present total segment profit and total segment margin that appear to be non-GAAP financial measures in MD&A. Please remove these non-GAAP measures or provide the disclosures required by Item 10(e) of Regulation S-K. Refer to Question 104.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. This comment also applies to your Forms 10-Q filed in fiscal year 2023. Non-GAAP Financial Measures, page 22 2.You record a tax impact of adjustments representing 2.7% of the total adjustments made in determining adjusted net income as compared to the GAAP effective tax rate of 24.8% in fiscal year 2022. Please expand your disclosure to clarify how you determined the tax
FirstName LastNameBert Nappier Comapany NameGenuine Parts Company August 3, 2023 Page 2 FirstName LastName Bert Nappier Genuine Parts Company August 3, 2023 Page 2 effect of non-GAAP adjustments in calculating the adjusted net income and adjusted diluted EPS in each reporting period presented. Refer to Question 102.11 of the Non- GAAP Financial Measures Compliance and Disclosure Interpretations. Consolidated Balance Sheet, page 36 3.Please state separately, in your balance sheet or in a note thereto, any elements of prepaid expenses and other current assets in excess of five percent of your total current assets. Refer to Rule 5-02(8) of Regulation S-X. In addition, please separately state any elements of other current liabilities in excess of five percent of your total current liabilities. Refer to Rule 5-02(20) of Regulation S-X. 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 Suying Li at (202) 551-3335 or Linda Cvrkel at (202) 551-3813 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
August 3, 2023
Bert Nappier
Executive Vice President and Chief Financial Officer
Genuine Parts Company
2999 Wildwood Parkway
Atlanta, GA 30339
Re:Genuine Parts Company
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 23, 2023
File No. 001-05690
Dear Bert Nappier:
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 Fiscal Year Ended December 31, 2022
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Consolidated Results of Operations, page 19
1.You present total segment profit and total segment margin that appear to be non-GAAP
financial measures in MD&A. Please remove these non-GAAP measures or provide the
disclosures required by Item 10(e) of Regulation S-K. Refer to Question 104.04 of the
Non-GAAP Financial Measures Compliance and Disclosure Interpretations. This
comment also applies to your Forms 10-Q filed in fiscal year 2023.
Non-GAAP Financial Measures, page 22
2.You record a tax impact of adjustments representing 2.7% of the total adjustments made
in determining adjusted net income as compared to the GAAP effective tax rate of 24.8%
in fiscal year 2022. Please expand your disclosure to clarify how you determined the tax
FirstName LastNameBert Nappier
Comapany NameGenuine Parts Company
August 3, 2023 Page 2
FirstName LastName
Bert Nappier
Genuine Parts Company
August 3, 2023
Page 2
effect of non-GAAP adjustments in calculating the adjusted net income and adjusted
diluted EPS in each reporting period presented. Refer to Question 102.11 of the Non-
GAAP Financial Measures Compliance and Disclosure Interpretations.
Consolidated Balance Sheet, page 36
3.Please state separately, in your balance sheet or in a note thereto, any elements of prepaid
expenses and other current assets in excess of five percent of your total current assets.
Refer to Rule 5-02(8) of Regulation S-X. In addition, please separately state any elements
of other current liabilities in excess of five percent of your total current liabilities. Refer
to Rule 5-02(20) of Regulation S-X.
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 Suying Li at (202) 551-3335 or Linda Cvrkel at (202) 551-3813 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services