SEC Comment Letter 0000000000-23-002411 to UNIVERSAL CORP /VA/ (UVV)
UNIVERSAL CORP /VA/
Date: March 13, 2023 · CIK: 0000102037 · Accession: 0000000000-23-002411
AI Filing Summary & Sentiment
File numbers found in text: 001-00652
Letter
United States securities and exchange commission logo March 13, 2023 George Freeman Chairman, President, and Chief Executive Officer Universal Corporation 9201 Forest Hill Avenue Richmond, VA 23235 Re:Universal Corporation Form 10-K for Fiscal Year Ended March 31, 2022 Filed May 27, 2022 File No. 001-00652 Dear George Freeman: We have reviewed your filing 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 March 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Financial Highlights Reconciliation of Certain Non-GAAP Financial Measures Adjusted Net Income and Diluted Earnings Per Share Reconciliation, page 29 1.Please revise your reconciliation to separately present the income tax effects related to the non-GAAP adjustments and provide an explanation of how the tax impacts are determined. Refer to Question 102.11 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameGeorge Freeman Comapany NameUniversal Corporation March 13, 2023 Page 2 FirstName LastName George Freeman Universal Corporation March 13, 2023 Page 2 Item 8. Financial Statements and Supplementary Data Consolidated Balance Sheets, page 45 2.Please present accounts payable separately from accrued expenses. Also, tell us and disclose with quantification as of each balance sheet date any component of accrued expenses exceeding the disclosure threshold. Refer to Rules 5-02.19 and .20 of Regulation S-X. Consolidated Statements of Cash Flows, page 47 3.Please breakout the line items under the changes in operating assets and liabilities, net section of your cash flows from operating activities into smaller components. For example, changes in inventories should be presented separately from other assets. Refer to ASC 230-10-45-29. 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 Suying Li at (202) 551-3335 or Rufus Decker at (202) 551-3769 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 13, 2023
George Freeman
Chairman, President, and Chief Executive Officer
Universal Corporation
9201 Forest Hill Avenue
Richmond, VA 23235
Re:Universal Corporation
Form 10-K for Fiscal Year Ended March 31, 2022
Filed May 27, 2022
File No. 001-00652
Dear George Freeman:
We have reviewed your filing 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 March 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Financial Highlights
Reconciliation of Certain Non-GAAP Financial Measures
Adjusted Net Income and Diluted Earnings Per Share Reconciliation, page 29
1.Please revise your reconciliation to separately present the income tax effects related to the
non-GAAP adjustments and provide an explanation of how the tax impacts are
determined. Refer to Question 102.11 of the Non-GAAP Financial Measures Compliance
and Disclosure Interpretations.
FirstName LastNameGeorge Freeman
Comapany NameUniversal Corporation
March 13, 2023 Page 2
FirstName LastName
George Freeman
Universal Corporation
March 13, 2023
Page 2
Item 8. Financial Statements and Supplementary Data
Consolidated Balance Sheets, page 45
2.Please present accounts payable separately from accrued expenses. Also, tell us and
disclose with quantification as of each balance sheet date any component of accrued
expenses exceeding the disclosure threshold. Refer to Rules 5-02.19 and .20 of
Regulation S-X.
Consolidated Statements of Cash Flows, page 47
3.Please breakout the line items under the changes in operating assets and liabilities, net
section of your cash flows from operating activities into smaller components. For
example, changes in inventories should be presented separately from other assets. Refer
to ASC 230-10-45-29.
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 Suying Li at (202) 551-3335 or Rufus Decker at (202) 551-3769 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services