SEC Comment Letter for NAPCO SECURITY TECHNOLOGIES, INC (NSSC) (CIK 0000069633) (NSSC) — May 3, 2005
NAPCO SECURITY TECHNOLOGIES, INC (NSSC) (CIK 0000069633)
Date: May 3, 2005 · CIK: 0000069633 · Accession: 0000000000-05-021393
AI Filing Summary & Sentiment
File numbers found in text: 000-10004
Referenced dates: April 8, 2005, March 22, 2005
Letter
May 3, 2005 Mr. Kevin S. Buchel Chief Financial Officer Napco Security Systems, Inc. 333 Bayview Avenue Amityville, NW 11701 Form 10-Q for the quarter ended September 30, 2004 Form 10-Q for the quarter ended December 31, 2004 File No. 000-10004
RE: Napco Security Systems, Inc. Form 10-K for the fiscal year ended June 30, 2004 Filed September 27, 2004
Dear Mr. Buchel:
We have reviewed your supplemental response letter dated April 8, 2005 as well as the above referenced filings and have the following comments. As noted in our comment letter dated March 22, 2005, we have limited our review to your financial statements and related disclosures and will make no further review of your documents. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.
Form 10-K for the year ended June 30, 2004
Item 7. Management`s Discussion and Analysis of Financial Condition and Results of Operations
1. We note your response to comment 2. We believe the increase in your inventory reserve balance of $1,035,000 is material and should be clearly explained to investors. Provide a sufficiently detailed, quantified discussion in your future MD&A inventory discussions, similar to the information provided to us in response to comment 2.
Note 5 - Income Taxes, pages FS-16 - FS-18
2. We note your response to comment 6. Provide in future filings a detailed discussion of the facts and circumstances concerning the tax issue and describe for readers the potential outcome should the IRS question Napco`s qualification for the exemption provided in IRC Section 943 (a)(4)(c). Refer to paragraph 10 of SFAS 5 and 10- 01(a)(5) of Regulation S-X.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental information. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Kenya Wright, Staff Accountant, at (202) 551- 3373 or Robert S. Littlepage Jr., Accountant Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551- with any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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<TEXT>
Mail Stop 04-07
May 3, 2005
Mr. Kevin S. Buchel
Chief Financial Officer
Napco Security Systems, Inc.
333 Bayview Avenue
Amityville, NW 11701
RE: Napco Security Systems, Inc.
Form 10-K for the fiscal year ended June 30, 2004
Filed September 27, 2004
Form 10-Q for the quarter ended September 30, 2004
Form 10-Q for the quarter ended December 31, 2004
File No. 000-10004
Dear Mr. Buchel:
We have reviewed your supplemental response letter dated
April
8, 2005 as well as the above referenced filings and have the
following comments. As noted in our comment letter dated March
22,
2005, we have limited our review to your financial statements and
related disclosures and will make no further review of your
documents. As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.
Form 10-K for the year ended June 30, 2004
Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations
1. We note your response to comment 2. We believe the increase in
your inventory reserve balance of $1,035,000 is material and
should
be clearly explained to investors. Provide a sufficiently
detailed,
quantified discussion in your future MD&A inventory discussions,
similar to the information provided to us in response to comment
2.
Note 5 - Income Taxes, pages FS-16 - FS-18
2. We note your response to comment 6. Provide in future filings a
detailed discussion of the facts and circumstances concerning the
tax
issue and describe for readers the potential outcome should the
IRS
question Napco`s qualification for the exemption provided in IRC
Section 943 (a)(4)(c). Refer to paragraph 10 of SFAS 5 and 10-
01(a)(5) of Regulation S-X.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information. Please file your response
letter
on EDGAR. Please understand that we may have additional comments
after reviewing your amendment and responses to our comments.
You may contact Kenya Wright, Staff Accountant, at (202)
551-
3373 or Robert S. Littlepage Jr., Accountant Branch Chief, at
(202)
551-3361 if you have questions regarding comments on the financial
statements and related matters. Please contact me at (202) 551-
3810
with any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Kevin S. Buchel
Napco Security Systems, Inc.
May 3, 2005
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