SEC Comment Letter for MATTHEWS INTERNATIONAL CORP (MATW) (CIK 0000063296) (MATW) — May 14, 2019
MATTHEWS INTERNATIONAL CORP (MATW) (CIK 0000063296)
Date: May 14, 2019 · CIK: 0000063296 · Accession: 0000000000-19-008419
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-09115
Letter
May 13, 2019 Steven Nicola Chief Financial Officer MATTHEWS INTERNATIONAL CORP Two Northshore Center Pittsburgh, PA. 15212 Re:MATTHEWS INTERNATIONAL CORP Form 10-K for the year ended September 30, 2018 Filed on November 20, 2018 Form 8-K filed on May 3, 2019 File No. 000-09115 Dear Mr. Nicola: 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 and any amendment you may file in response to these comments, we may have additional comments. Form 10-K for the period ended September 30, 2018 Long-Term Debt, page 52 1.With respect to your $11.2 million receivable recorded in Other Assets related to amounts drawn upon a letter of credit issued by the Company, please tell us and expand your disclosures herein, or within your Critical Accounting Policies section, to address how the Company continually assesses the collectability of this receivable and address any material underlying judgments and assumptions involved in this assessment. Item 2.02 of Form 8-K filed May 2, 2019 General 2.Please revise the bullet point highlights to also present the corresponding GAAP measure
FirstName LastNameSteven Nicola Comapany NameMATTHEWS INTERNATIONAL CORP May 13, 2019 Page 2 FirstName LastName Steven Nicola MATTHEWS INTERNATIONAL CORP May 13, 2019 Page 2 related to Adjusted EBITDA with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Non-GAAP Compliance and Disclosure Interpretations. 3.Please revise your disclosures to provide a reconciliation of Adjusted EPS to GAAP EPS in accordance with Item 10(e)(1)(i)(b) of Regulation S-K. 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 Ameen Hamady at 202-551-3891 or in his absence, Jeanne Baker at 202-551-3691 if you have questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction
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May 13, 2019
Steven Nicola
Chief Financial Officer
MATTHEWS INTERNATIONAL CORP
Two Northshore Center
Pittsburgh, PA. 15212
Re:MATTHEWS INTERNATIONAL CORP
Form 10-K for the year ended September 30, 2018
Filed on November 20, 2018
Form 8-K filed on May 3, 2019
File No. 000-09115
Dear Mr. Nicola:
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 and any amendment you may file in response to these
comments, we may have additional comments.
Form 10-K for the period ended September 30, 2018
Long-Term Debt, page 52
1.With respect to your $11.2 million receivable recorded in Other Assets related to amounts
drawn upon a letter of credit issued by the Company, please tell us and expand your
disclosures herein, or within your Critical Accounting Policies section, to address how the
Company continually assesses the collectability of this receivable and address
any material underlying judgments and assumptions involved in this assessment.
Item 2.02 of Form 8-K filed May 2, 2019
General
2.Please revise the bullet point highlights to also present the corresponding GAAP measure
FirstName LastNameSteven Nicola
Comapany NameMATTHEWS INTERNATIONAL CORP
May 13, 2019 Page 2
FirstName LastName
Steven Nicola
MATTHEWS INTERNATIONAL CORP
May 13, 2019
Page 2
related to Adjusted EBITDA with equal or greater prominence. Refer to Item
10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Non-GAAP Compliance and
Disclosure Interpretations.
3.Please revise your disclosures to provide a reconciliation of Adjusted EPS to GAAP EPS
in accordance with Item 10(e)(1)(i)(b) of Regulation S-K.
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 Ameen Hamady at 202-551-3891 or in his absence, Jeanne
Baker at 202-551-3691 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction