SEC Comment Letter for NATIONAL RESEARCH CORP (NRC) (CIK 0000070487) (NRC) — Aug 31, 2022
NATIONAL RESEARCH CORP (NRC) (CIK 0000070487)
Date: Aug. 31, 2022 · CIK: 0000070487 · Accession: 0000000000-22-009463
AI Filing Summary & Sentiment
File numbers found in text: 001-35929
Letter
United States securities and exchange commission logo August 31, 2022 Kevin Karas Chief Financial Officer National Research Corporation 1245 Q Street Lincoln, Nebraska 68508 Re:National Research Corporation Form 10-K for the Year Ended December 31, 2021 Filed March 4, 2022 File No. 001-35929 Dear Mr. Karas: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the Year Ended December 31, 2021 Managements Discussion and Analysis of Financial Condition and Results of Operations Key Financial Metrics and Results of Operations, page 18 1.When several factors attribute to material fluctuations in your results of operations, please quantify each factor cited so that investors may understand the magnitude and relative impact of each factor. Refer to Item 303 of Regulation S-K. Item 8. Financial Statements and Supplementary Data Notes to Consolidated Financial Statements (13) Segment Information , page 50 2.We note in March 2021 you changed your operating segments from six to one to reflect a change in corporate reporting structure to the Chief Executive Officer and chief operating decision maker (CODM). Please provide more information about this change, including
FirstName LastNameKevin Karas Comapany NameNational Research Corporation August 31, 2022 Page 2 FirstName LastName Kevin Karas National Research Corporation August 31, 2022 Page 2 how your CODM received and receives information about your different lines of business, how resources are shared or allocated to these different lines of business, and why the change in corporate structure occurred. In closing, 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 Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
August 31, 2022
Kevin Karas
Chief Financial Officer
National Research Corporation
1245 Q Street
Lincoln, Nebraska 68508
Re:National Research Corporation
Form 10-K for the Year Ended December 31, 2021
Filed March 4, 2022
File No. 001-35929
Dear Mr. Karas:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Year Ended December 31, 2021
Managements Discussion and Analysis of Financial Condition and Results of Operations
Key Financial Metrics and Results of Operations, page 18
1.When several factors attribute to material fluctuations in your results of operations, please
quantify each factor cited so that investors may understand the magnitude and relative
impact of each factor. Refer to Item 303 of Regulation S-K.
Item 8. Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
(13) Segment Information , page 50
2.We note in March 2021 you changed your operating segments from six to one to reflect a
change in corporate reporting structure to the Chief Executive Officer and chief operating
decision maker (CODM). Please provide more information about this change, including
FirstName LastNameKevin Karas
Comapany NameNational Research Corporation
August 31, 2022 Page 2
FirstName LastName
Kevin Karas
National Research Corporation
August 31, 2022
Page 2
how your CODM received and receives information about your different lines of business,
how resources are shared or allocated to these different lines of business, and why the
change in corporate structure occurred.
In closing, 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 Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services