SEC Comment Letter for POWELL INDUSTRIES INC (POWL) (CIK 0000080420) (POWL) — Feb 26, 2020
POWELL INDUSTRIES INC (POWL) (CIK 0000080420)
Date: Feb. 26, 2020 · CIK: 0000080420 · Accession: 0000000000-20-001745
AI Filing Summary & Sentiment
File numbers found in text: 001-12488
Letter
February 26, 2020 Michael W. Metcalf Chief Financial Officer Powell Industries, Inc. 8550 Mosley Road Houston, Texas 77075-1180 Re:Powell Industries, Inc. Form 10-K for the Fiscal Year Ended September 30, 2019 Filed December 5, 2019 File No. 001-12488 Dear Mr. Metcalf: 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 Fiscal Year Ended September 30, 2019 Financial Statements Notes to Consolidated Financial Statements M. Geographic Information, page 52 1.Please revise to disclose your operating and reporting segments and provide all disclosures required by ASC 280-10-50. Your response should fully address your reporting structure regarding those executive positions that report to the CODM. In this regard, we note that you have multiple market sectors per page 42 and categories of revenue per page 18 including commercial and industrial revenues, public and private utilities revenues, and municipal and transit revenues. N. Quarterly Information , page 53 2.During the fiscal years ended September 30, 2019 and 2018, the quarterly data shows significant fluctuations in operating results between the quarters. Specifically, there are
FirstName LastNameMichael W. Metcalf Comapany NamePowell Industries, Inc. February 26, 2020 Page 2 FirstName LastName Michael W. Metcalf Powell Industries, Inc. February 26, 2020 Page 2 large variations in revenues, gross profit, and net income (loss). Please revise to add a discussion of any unusual or infrequently occurring items during each quarter, which may have contributed to the significant fluctuations in operating results. Refer to Item 302(a)(3) of Regulation S-K. 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 Heather Clark at 202-551-3624 or Melissa Raminpour at 202-551- 3379 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
February 26, 2020
Michael W. Metcalf
Chief Financial Officer
Powell Industries, Inc.
8550 Mosley Road
Houston, Texas 77075-1180
Re:Powell Industries, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2019
Filed December 5, 2019
File No. 001-12488
Dear Mr. Metcalf:
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 Fiscal Year Ended September 30, 2019
Financial Statements
Notes to Consolidated Financial Statements
M. Geographic Information, page 52
1.Please revise to disclose your operating and reporting segments and provide all
disclosures required by ASC 280-10-50. Your response should fully address your
reporting structure regarding those executive positions that report to the CODM. In this
regard, we note that you have multiple market sectors per page 42 and categories of
revenue per page 18 including commercial and industrial revenues, public and private
utilities revenues, and municipal and transit revenues.
N. Quarterly Information , page 53
2.During the fiscal years ended September 30, 2019 and 2018, the quarterly data shows
significant fluctuations in operating results between the quarters. Specifically, there are
FirstName LastNameMichael W. Metcalf
Comapany NamePowell Industries, Inc.
February 26, 2020 Page 2
FirstName LastName
Michael W. Metcalf
Powell Industries, Inc.
February 26, 2020
Page 2
large variations in revenues, gross profit, and net income (loss). Please revise to add a
discussion of any unusual or infrequently occurring items during each quarter, which may
have contributed to the significant fluctuations in operating results. Refer to Item
302(a)(3) of Regulation S-K.
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 Heather Clark at 202-551-3624 or Melissa Raminpour at 202-551-
3379 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing