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SEC Comment Letter 0000000000-23-004639 to SHERWIN WILLIAMS CO (SHW)

SHERWIN WILLIAMS CO
Date: May 4, 2023 · CIK: 0000089800 · Accession: 0000000000-23-004639

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File numbers found in text: 001-04851

Date
May 4, 2023
Author
Allen J. Mistysyn
Form
UPLOAD
Company
SHERWIN WILLIAMS CO

Letter

United States securities and exchange commission logo May 4, 2023 Allen J. Mistysyn Chief Financial Officer The Sherwin-Williams Company 101 West Prospect Avenue Cleveland, Ohio 44115-1075 Re:The Sherwin-Williams Company Form 10-K for Fiscal Year Ended December 31, 2022 File No. 001-04851 Filed February 22, 2023 Dear Allen J. Mistysyn: 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 Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis Results of Operations, page 23 1.Please quantify the extent to which changes in revenue are attributable to changes in prices and volumes. For example, you disclose that net sales in The Americas Group increased primarily due to selling price increases as well as volume growth in all end markets, particularly residential repaint, but do not quantify these factors. Refer to Item 303(b)(2)(iii) of Regulation S-K.

FirstName LastNameAllen J. Mistysyn Comapany NameThe Sherwin-Williams Company May 4, 2023 Page 2 FirstName LastName Allen J. Mistysyn The Sherwin-Williams Company May 4, 2023 Page 2 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 Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services

Show Raw Text
United States securities and exchange commission logo
May 4, 2023
Allen J. Mistysyn
Chief Financial Officer
The Sherwin-Williams Company
101 West Prospect Avenue
Cleveland, Ohio 44115-1075
Re:The Sherwin-Williams Company
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 001-04851
Filed February 22, 2023
Dear Allen J. Mistysyn:
            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 Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis
Results of Operations, page 23
1.Please quantify the extent to which changes in revenue are attributable to changes in
prices and volumes.  For example, you disclose that net sales in The Americas Group
increased primarily due to selling price increases as well as volume growth in all end
markets, particularly residential repaint, but do not quantify these factors.  Refer to Item
303(b)(2)(iii) of Regulation S-K.

 FirstName LastNameAllen J.  Mistysyn
 Comapany NameThe Sherwin-Williams Company
 May 4, 2023 Page 2
 FirstName LastName
Allen J.  Mistysyn
The Sherwin-Williams Company
May 4, 2023
Page 2
            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 Lyn Shenk at 202-551-3380 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services