SEC Comment Letter for UNIVERSAL (UVV) — Jan 22, 2013
UNIVERSAL CORP /VA/ (UVV) (CIK 0000102037)
Date: Jan. 22, 2013 · CIK: 0000102037 · Accession: 0000000000-13-003565
AI Filing Summary & Sentiment
Letter
January 22, 2013 David C. Moore - Chief Financial Officer Universal Corporation 9201 Forest Hill Avenue Richmond, Virginia 23235
Re: Universal Corporation Form 10-K for the fiscal year ended March 31, 2012 Filed May 25, 2012 File No. 001 -00652
Dear Mr. Moore :
We have reviewed your filing an d have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comment s.
Form 10 -K for the fiscal year ended March 31, 2012
Notes to Consolidated Financial Statements
Note 1. Nature of Operations and Significant Accounting Policies, page 45
Recoverable Value -Added Tax Credits, page 47
1. With regard to the au dit of your inter-state VAT filings by tax authorities in Brazil, you indicate that no liability has been recorded at March 31, 2012, as no loss is considered probable at this time. If there is at least a reasonable possibility that a loss may have been incurred, in your next periodic filing, please either disclose an estimate (or, if true, state that the estimate is immaterial in lieu of providing qu antified amounts) of the loss or range of loss, or state that s uch an estimate cannot be made. R efer to AS C 450 -20-50. Please include your proposed disclosures in your response.
David C. Moore Universal Corporation January 22, 2013 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange A ct of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comment , please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the Uni ted States.
You may contact Juan Migone at (202) 551 -3312 or me at (202) 551 -3211 if you have any question s.
Sincerely,
/s/ David R. Humphrey
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January 22, 2013 David C. Moore - Chief Financial Officer Universal Corporation 9201 Forest Hill Avenue Richmond, Virginia 23235 Re: Universal Corporation Form 10-K for the fiscal year ended March 31, 2012 Filed May 25, 2012 File No. 001 -00652 Dear Mr. Moore : We have reviewed your filing an d have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comment s. Form 10 -K for the fiscal year ended March 31, 2012 Notes to Consolidated Financial Statements Note 1. Nature of Operations and Significant Accounting Policies, page 45 Recoverable Value -Added Tax Credits, page 47 1. With regard to the au dit of your inter-state VAT filings by tax authorities in Brazil, you indicate that no liability has been recorded at March 31, 2012, as no loss is considered probable at this time. If there is at least a reasonable possibility that a loss may have been incurred, in your next periodic filing, please either disclose an estimate (or, if true, state that the estimate is immaterial in lieu of providing qu antified amounts) of the loss or range of loss, or state that s uch an estimate cannot be made. R efer to AS C 450 -20-50. Please include your proposed disclosures in your response. David C. Moore Universal Corporation January 22, 2013 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange A ct of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment , please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the Uni ted States. You may contact Juan Migone at (202) 551 -3312 or me at (202) 551 -3211 if you have any question s. Sincerely, /s/ David R. Humphrey David R. Humphrey Accounting Branch Chief