SEC Comment Letter 0000000000-24-014008 to MAUI LAND & PINEAPPLE CO INC (MLP)
MAUI LAND & PINEAPPLE CO INC
Date: Dec. 19, 2024 · CIK: 0000063330 · Accession: 0000000000-24-014008
AI Filing Summary & Sentiment
File numbers found in text: 001-06510
Referenced dates: October 17, 2024
Letter
December 19, 2024 Wade Kodama Chief Financial Officer Maui Land & Pineapple Company, Inc. 500 Office Road Lahaina, HI 96761 Re:Maui Land & Pineapple Company, Inc. Form 10-K for the year ended December 31, 2023 Filed March 28, 2024 File No. 001-06510 Dear Wade Kodama: We have reviewed your November 6, 2024 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our October 17, 2024 letter. Form 10-K for the year ended December 31, 2023 Note 5. Investment in Joint Venture, page 32 1.We have considered your response to comment 2 in our letter dated October 17, 2024. Given the quantitative significance of the error and that we do not agree that the factors cited in your qualitative assessment overcome such significance, we disagree with your conclusion that the error was immaterial. Accordingly, we have concluded that your consolidated financial statements for the year ended December 31, 2023 are materially misstated and, therefore, should be restated. Also, in light of the restatement, please reassess your conclusions regarding disclosure controls and procedures and internal control over financial reporting for the impacted periods. Please contact Ameen Hamady at 202-551-3891 or Kristina Marrone at 202-551-3429 if you have questions regarding comments on the financial statements and related matters.
December 19, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
December 19, 2024
Wade Kodama
Chief Financial Officer
Maui Land & Pineapple Company, Inc.
500 Office Road
Lahaina, HI 96761
Re:Maui Land & Pineapple Company, Inc.
Form 10-K for the year ended December 31, 2023
Filed March 28, 2024
File No. 001-06510
Dear Wade Kodama:
We have reviewed your November 6, 2024 response to our comment letter and have
the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Unless we note otherwise, any references to prior comments are to comments in our October
17, 2024 letter.
Form 10-K for the year ended December 31, 2023
Note 5. Investment in Joint Venture, page 32
1.We have considered your response to comment 2 in our letter dated October 17,
2024. Given the quantitative significance of the error and that we do not agree that
the factors cited in your qualitative assessment overcome such significance, we
disagree with your conclusion that the error was immaterial. Accordingly, we have
concluded that your consolidated financial statements for the year ended December
31, 2023 are materially misstated and, therefore, should be restated. Also, in light of
the restatement, please reassess your conclusions regarding disclosure controls and
procedures and internal control over financial reporting for the impacted periods.
Please contact Ameen Hamady at 202-551-3891 or Kristina Marrone at 202-551-3429
if you have questions regarding comments on the financial statements and related matters.
December 19, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction