SEC Comment Letter for IEH Corp (IEHC) (CIK 0000050292) (IEHC) — Feb 27, 2020
IEH Corp (IEHC) (CIK 0000050292)
Date: Feb. 27, 2020 · CIK: 0000050292 · Accession: 0000000000-20-001760
AI Filing Summary & Sentiment
File numbers found in text: 000-05278
Letter
February 27, 2020 Robert Knoth Chief Financial Officer IEH Corporation 140 58th Street, Suite 8E Brooklyn, New York 11220 Re:IEH Corporation Form 10-K for the Fiscal Year Ended March 29, 2019 Response dated February 10, 2020 Form 10-Q for the Quarterly Period Ended December 31, 2019 File No. 000-05278 Dear Mr. Knoth: We have reviewed your February 10, 2020 response to our comment letter and subsequent filings, 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. Unless we note otherwise, our references to prior comments are to comments in our January 13, 2020 letter. Form 10-K for the Fiscal Year Ended March 29, 2019 Management's Report on Internal Control over Financial Reporting, page 23 1.We reviewed your response to our prior comment one. Please include the reference to the COSO 2013 framework in all future filings, including your amendment. Financial Statements Report of Independent Registered Public Accounting Firm, page 39 2.We note your response to our prior comment three. Please file an amendment to include the revised audit report.
FirstName LastNameRobert Knoth Comapany NameIEH Corporation February 27, 2020 Page 2 FirstName LastName Robert Knoth IEH Corporation February 27, 2020 Page 2 Form 10-Q for the Quarterly Period Ended December 31, 2019 Statements of Changes in Stockholder's Equity, page 7 3.In all future quarterly filings, please include statements of changes in stockholder's equity that present the information required by Rule 3-04 of Regulation S-X for the current and comparative year-to-date periods, with subtotals for each interim period. Refer to Rule 8- 03(a)(5) of Regulation S-X. Notes to Financial Statements Note 2 – Summary of Significant Accounting Policies Correction of an Immaterial Misstatement in a Prior Period Financial Statement , page 12 4.We note your disclosure regarding the error in your financial statements, pertaining to stock based compensation. Please provide us with a comprehensive analysis regarding your conclusion that an amendment to the financial statements for the quarterly period ended September 27, 2019 was not necessary. You may contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723 if you have questions regarding comments. Sincerely, Division of Corporation Finance Office of Manufacturing
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February 27, 2020
Robert Knoth
Chief Financial Officer
IEH Corporation
140 58th Street, Suite 8E
Brooklyn, New York 11220
Re:IEH Corporation
Form 10-K for the Fiscal Year Ended March 29, 2019
Response dated February 10, 2020
Form 10-Q for the Quarterly Period Ended December 31, 2019
File No. 000-05278
Dear Mr. Knoth:
We have reviewed your February 10, 2020 response to our comment letter and
subsequent filings, 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. Unless we note otherwise, our references to prior comments are to comments in our
January 13, 2020 letter.
Form 10-K for the Fiscal Year Ended March 29, 2019
Management's Report on Internal Control over Financial Reporting, page 23
1.We reviewed your response to our prior comment one. Please include the reference to the
COSO 2013 framework in all future filings, including your amendment.
Financial Statements
Report of Independent Registered Public Accounting Firm, page 39
2.We note your response to our prior comment three. Please file an amendment to include
the revised audit report.
FirstName LastNameRobert Knoth
Comapany NameIEH Corporation
February 27, 2020 Page 2
FirstName LastName
Robert Knoth
IEH Corporation
February 27, 2020
Page 2
Form 10-Q for the Quarterly Period Ended December 31, 2019
Statements of Changes in Stockholder's Equity, page 7
3.In all future quarterly filings, please include statements of changes in stockholder's equity
that present the information required by Rule 3-04 of Regulation S-X for the current and
comparative year-to-date periods, with subtotals for each interim period. Refer to Rule 8-
03(a)(5) of Regulation S-X.
Notes to Financial Statements
Note 2 – Summary of Significant Accounting Policies
Correction of an Immaterial Misstatement in a Prior Period Financial Statement , page 12
4.We note your disclosure regarding the error in your financial statements, pertaining to
stock based compensation. Please provide us with a comprehensive analysis regarding
your conclusion that an amendment to the financial statements for the quarterly period
ended September 27, 2019 was not necessary.
You may contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Manufacturing