Correspondence 0000950103-24-005993 from MASCO CORP /DE/ (MAS) (CIK 0000062996) (MAS)
MASCO CORP /DE/ (MAS) (CIK 0000062996)
Date: April 30, 2024 · CIK: 0000062996 · Accession: 0000950103-24-005993
AI Filing Summary & Sentiment
File numbers found in text: 001-05794
Referenced dates: April 4, 2024
Letter
VIA EDGAR TRANSMISSION (CORRESP.) Division of Corporation Finance Office of Manufacturing and Construction Attention: Mr. Kevin Stertzel Re: Masco Corporation Form 10-K for Fiscal Year Ended December 31, 2023 Filed February 8, 2024 File No. 001-05794
Dear Mr. Stertzel:
On behalf of Masco Corporation (the “Company”), I am writing to respond to the Staff of the Securities and Exchange Commission’s comments with respect to the above-referenced Form 10-K in the Staff’s letter dated April 4, 2024. The numbered paragraphs below correspond to the headings and numbers set forth in the comment letter, the text of which is copied in italics for your reference.
Form 10-K for the Fiscal Year ended December 31, 2023
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Consolidated Results of Operations, page 19
1. We note your Results of Operations disclosures identify various factors which positively or negatively impacted your results. In future filings, please quantify in dollar or percentage terms, the impact each factor had on the measure of profitability or expense you discuss. Refer to the Commission's MD&A Interpretive guidance found in Commission Release No. 33-8350 as well as Item 303 of Regulation S-K.
Response:
The Company respectfully acknowledges the Staff’s comment and confirms that, in future filings beginning with our Form 10-Q for the quarterly period ended June 30, 2024, when two or more factors contribute to a material change in a measure of profitability or expense we discuss, the Company will quantify the impact of each such factor, in dollar or percentage terms, where such quantification is practicable and necessary to an understanding of the material change in the measure of profitability or expense.
Mr. Kevin Stertzel
April 30, 2024
Financial Statements
Note I. Supplier Finance Program, page 53
2. In future filings, please provide all disclosures contemplated in ASC 405-50-50-3(a) including a description of the payment terms and whether any assets are pledged as security or other forms of guarantees.
Response:
The Company respectfully acknowledges the Staff’s comment and confirms that in future filings, the Company will provide all disclosures contemplated in ASC 405-50-50-3(a). With respect to payment terms, in our Form 10-Q for the quarterly period ended March 31, 2024, the Company provided a range of payment terms associated with a majority of our suppliers in Note G, Supplier Finance Program. With respect to any assets pledged as security or other forms of guarantees, currently, under the Company’s voluntary supply chain finance program, the Company does not pledge assets as security or provide other forms of guarantees to the participating financial institutions or third-party administrator. To the extent the Company pledges assets as security or provides other forms of guarantees in the future, the Company will modify and incorporate into its disclosures, as appropriate.
If you have any further questions or comments, please contact me at 313-792-6021.
Sincerely,
/s/ Richard J. Westenberg
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Masco Corporation
17450 College Parkway
Livonia, Michigan 48152
313 274 7400
www.masco.com
April 30, 2024
VIA EDGAR TRANSMISSION (CORRESP.)
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing and Construction
100 F Street, NE
Washington, DC 20549-4561
Attention: Mr. Kevin Stertzel
Re:
Masco Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
Filed February 8, 2024
File No. 001-05794
Dear Mr. Stertzel:
On behalf of Masco Corporation (the “Company”),
I am writing to respond to the Staff of the Securities and Exchange Commission’s comments with respect to the above-referenced Form
10-K in the Staff’s letter dated April 4, 2024. The numbered paragraphs below correspond to the headings and numbers set forth in
the comment letter, the text of which is copied in italics for your reference.
Form 10-K for the Fiscal Year ended December 31, 2023
Management’s Discussion and Analysis of Financial
Condition and Results of Operations
Consolidated Results of Operations, page 19
1. We note your Results of Operations disclosures identify various factors which positively or negatively
impacted your results. In future filings, please quantify in dollar or percentage terms, the impact each factor had on the measure of
profitability or expense you discuss. Refer to the Commission's MD&A Interpretive guidance found in Commission Release No. 33-8350
as well as Item 303 of Regulation S-K.
Response:
The Company respectfully acknowledges the Staff’s
comment and confirms that, in future filings beginning with our Form 10-Q for the quarterly period ended June 30, 2024, when two or more
factors contribute to a material change in a measure of profitability or expense we discuss, the Company will quantify the impact of each
such factor, in dollar or percentage terms, where such quantification is practicable and necessary to an understanding of the material
change in the measure of profitability or expense.
Mr. Kevin Stertzel
April 30, 2024
Financial Statements
Note I. Supplier Finance Program, page 53
2. In future filings, please provide all disclosures contemplated in ASC 405-50-50-3(a) including a description of the payment terms
and whether any assets are pledged as security or other forms of guarantees.
Response:
The Company respectfully acknowledges the Staff’s
comment and confirms that in future filings, the Company will provide all disclosures contemplated in ASC 405-50-50-3(a). With respect
to payment terms, in our Form 10-Q for the quarterly period ended March 31, 2024, the Company provided a range of payment terms associated
with a majority of our suppliers in Note G, Supplier Finance Program. With respect to any assets pledged as security or other forms
of guarantees, currently, under the Company’s voluntary supply chain finance program, the Company does not pledge assets as security
or provide other forms of guarantees to the participating financial institutions or third-party administrator. To the extent the
Company pledges assets as security or provides other forms of guarantees in the future, the Company will modify and incorporate into its
disclosures, as appropriate.
If you have any further questions or comments,
please contact me at 313-792-6021.
Sincerely,
/s/ Richard J. Westenberg
Richard J. Westenberg
Vice President, Chief Financial Officer and Treasurer