SEC Comment Letter 0000000000-23-013842 to PARK AEROSPACE CORP (PKE) (CIK 0000076267) (PKE)
PARK AEROSPACE CORP (PKE) (CIK 0000076267)
Date: Dec. 19, 2023 · CIK: 0000076267 · Accession: 0000000000-23-013842
AI Filing Summary & Sentiment
File numbers found in text: 001-04415
Letter
United States securities and exchange commission logo December 19, 2023 P. Matthew Farabaugh Chief Financial Officer Park Aerospace Corp. 1400 Old Country Road Westbury, NY 11590 Re:Park Aerospace Corp. Form 10-K for Fiscal Year Ended February 26, 2023 Form 8-K Filed May 11, 2023 File No. 001-04415 Dear P. Matthew Farabaugh: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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. Form 10-K filed May 12, 2023 Financial Statements Note 4 - Income Taxes, page 48 1.We note the line item in your rate reconciliation described as "ASC 740-10 change." It appears this reconciling item may relate to the change in uncertain tax positions. Please confirm our understanding and, in future filings, modify the description of this line item to more clearly convey the nature of the adjustment.
FirstName LastNameP. Matthew Farabaugh Comapany NamePark Aerospace Corp. December 19, 2023 Page 2 FirstName LastName P. Matthew Farabaugh Park Aerospace Corp. December 19, 2023 Page 2 Form 8-K Filed May 11, 2023 Reconciliation of Non-GAAP Financial Measures, page 6 2.We note that you present Adjusted EBITDA as a non-GAAP performance measure. However, your reconciliation does not reconcile Adjusted EBITDA to the most directly comparable GAAP measure, net income (loss), as required by Item 10(e)(1)(i)(B) of Regulation S-K. Please revise your presentation in future filings accordingly. Additionally, in future filings, please revise the format of the non-GAAP reconciliation to eliminate the partial non-GAAP income statement currently presented. Refer to the guidance in Question 102.10 of the Division's Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. 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. Please contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at 202-551-3723 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
December 19, 2023
P. Matthew Farabaugh
Chief Financial Officer
Park Aerospace Corp.
1400 Old Country Road
Westbury, NY 11590
Re:Park Aerospace Corp.
Form 10-K for Fiscal Year Ended February 26, 2023
Form 8-K Filed May 11, 2023
File No. 001-04415
Dear P. Matthew Farabaugh:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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.
Form 10-K filed May 12, 2023
Financial Statements
Note 4 - Income Taxes, page 48
1.We note the line item in your rate reconciliation described as "ASC 740-10 change." It
appears this reconciling item may relate to the change in uncertain tax positions. Please
confirm our understanding and, in future filings, modify the description of this line item to
more clearly convey the nature of the adjustment.
FirstName LastNameP. Matthew Farabaugh
Comapany NamePark Aerospace Corp.
December 19, 2023 Page 2
FirstName LastName
P. Matthew Farabaugh
Park Aerospace Corp.
December 19, 2023
Page 2
Form 8-K Filed May 11, 2023
Reconciliation of Non-GAAP Financial Measures, page 6
2.We note that you present Adjusted EBITDA as a non-GAAP performance measure.
However, your reconciliation does not reconcile Adjusted EBITDA to the most directly
comparable GAAP measure, net income (loss), as required by Item 10(e)(1)(i)(B) of
Regulation S-K. Please revise your presentation in future filings accordingly.
Additionally, in future filings, please revise the format of the non-GAAP reconciliation to
eliminate the partial non-GAAP income statement currently presented. Refer to the
guidance in Question 102.10 of the Division's Compliance & Disclosure Interpretations on
Non-GAAP Financial Measures.
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.
Please contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at 202-551-3723 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing