SEC Comment Letter for HEICO (HEI) — Oct 16, 2019
HEICO CORP
Date: Oct. 16, 2019 · CIK: 0000046619 · Accession: 0000000000-19-014599
AI Filing Summary & Sentiment
File numbers found in text: 001-04604
Letter
October 16, 2019 Carlos Macau, Jr. Chief Financial Officer HEICO CORP 3000 Taft Street Hollywood, FL 33021 Re:HEICO CORP Form 10-K for the period ended October 31, 2018 Filed December 20, 2018 File No. 001-04604 Dear Mr. Macau: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to our comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to our comment, we may have additional comments. Form 10-K for the period ended October 31, 2018 filed December 20, 2018 Management's Discussion and Analysis of Financial Condition and Results of Operations Contractual Obligations, page 48 1.We note you exclude interest charges on borrowings from your Long-term debt obligations caption in your Contractual Obligations table. It appears that your interest expenses are increasing significantly year over year and the trend is continuing as of your 10-Q for the period ended July 31, 2019. In light of this, please revise to include the estimated interest expense either in the table of contractual obligations or in a footnote disclosure below the table. Amounts may be based upon factors available as of the balance sheet date and disclosure should also include descriptive language that the balances may fluctuate based on future events and assumptions. Refer to footnote 46 of SEC Interpretive Release 33-8350 dated December 19, 2003. In closing, 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
FirstName LastNameCarlos Macau, Jr. Comapany NameHEICO CORP October 16, 2019 Page 2 FirstName LastName Carlos Macau, Jr. HEICO CORP October 16, 2019 Page 2 absence of action by the staff. You may contact Charles Eastman, Staff Accountant at (202)-551-3794 or Claire Erlanger, Staff Accountant at (202) 551-3301 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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October 16, 2019
Carlos Macau, Jr.
Chief Financial Officer
HEICO CORP
3000 Taft Street
Hollywood, FL 33021
Re:HEICO CORP
Form 10-K for the period ended October 31, 2018
Filed December 20, 2018
File No. 001-04604
Dear Mr. Macau:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to our comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to our comment, we may have additional comments.
Form 10-K for the period ended October 31, 2018 filed December 20, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Contractual Obligations, page 48
1.We note you exclude interest charges on borrowings from your Long-term debt
obligations caption in your Contractual Obligations table. It appears that your interest
expenses are increasing significantly year over year and the trend is continuing as of your
10-Q for the period ended July 31, 2019. In light of this, please revise to include the
estimated interest expense either in the table of contractual obligations or in a footnote
disclosure below the table. Amounts may be based upon factors available as of the balance
sheet date and disclosure should also include descriptive language that the balances may
fluctuate based on future events and assumptions. Refer to footnote 46 of SEC Interpretive
Release 33-8350 dated December 19, 2003.
In closing, 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
FirstName LastNameCarlos Macau, Jr.
Comapany NameHEICO CORP
October 16, 2019 Page 2
FirstName LastName
Carlos Macau, Jr.
HEICO CORP
October 16, 2019
Page 2
absence of action by the staff.
You may contact Charles Eastman, Staff Accountant at (202)-551-3794 or Claire
Erlanger, Staff Accountant at (202) 551-3301 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing