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SEC Comment Letter 0000000000-23-000904 to STANDEX INTERNATIONAL CORP/DE/ (SXI) (CIK 0000310354) (SXI)

STANDEX INTERNATIONAL CORP/DE/ (SXI) (CIK 0000310354)
Date: Jan. 26, 2023 · CIK: 0000310354 · Accession: 0000000000-23-000904

Financial Reporting Revenue Recognition Internal Controls

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File numbers found in text: 001-07233

Date
January 26, 2023
Author
David Dunbar
Form
UPLOAD
Company
STANDEX INTERNATIONAL CORP/DE/ (SXI) (CIK 0000310354)

Letter

United States securities and exchange commission logo January 26, 2023 David Dunbar President/Chief Executive Officer Standex International Corporation 23 Keewaydin Drive Salem, New Hampshire 03079 Re:Standex International Corporation Form 10-K for the Fiscal Year Ended June 30, 2022 Filed August 5, 2022 File No. 001-07233 Dear David Dunbar: 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 June 30, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 18 1.You had income from continuing operations before income taxes of $11,885 on revenues of $429,368 in the United States in 2022. This represents an income from continuing operations before income taxes margin of 2.8%. You had income from continuing operations of $69,404 on revenues of $305,971 outside the United States in 2022. This represents an income from continuing operations before income taxes margin of 22.7%. Please discuss and analyze the reasons for the low income from continuing operations before income taxes in the United States and the higher income from continuing operations before income taxes outside the United States.

FirstName LastNameDavid Dunbar Comapany NameStandex International Corporation January 26, 2023 Page 2 FirstName LastName David Dunbar Standex International Corporation January 26, 2023 Page 2 Gross Profit, page 20 2.Please quantify the factors that contributed to an increase or decrease in your gross profit. Organic sales growth is one of the factors that accounts for increases in your gross profit. Revise to disclose the drivers of organic sales growth. Since cost of sales likely increase with sales increases, discuss the relative impact of increases in cost of sales on your gross profit margins. If product mix contributes to changes in gross profit margin, discuss the impact of product mix and the products that are the primary contributors. Lastly, disclose what impact inflation had on your costs of sales and margins. Refer to Item 303 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 Robert Babula, Staff Accountant at (202) 551-3339, or Gus Rodriguez, Branch Chief at (202) 551-3752 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation

Show Raw Text
United States securities and exchange commission logo
January 26, 2023
David Dunbar
President/Chief Executive Officer
Standex International Corporation
23 Keewaydin Drive
Salem, New Hampshire 03079
Re:Standex International Corporation
Form 10-K for the Fiscal Year Ended June 30, 2022
Filed August 5, 2022
File No. 001-07233
Dear David Dunbar:
            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 June 30, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 18
1.You had income from continuing operations before income taxes of $11,885 on revenues
of $429,368 in the United States in 2022.  This represents an income from continuing
operations before income taxes margin of 2.8%.  You had income from continuing
operations of $69,404 on revenues of $305,971 outside the United States in 2022.  This
represents an income from continuing operations before income taxes margin of 22.7%.
Please discuss and analyze the reasons for the low income from continuing operations
before income taxes in the United States and the higher income from continuing
operations before income taxes outside the United States.

 FirstName LastNameDavid Dunbar
 Comapany NameStandex International Corporation
 January 26, 2023 Page 2
 FirstName LastName
David Dunbar
Standex International Corporation
January 26, 2023
Page 2
Gross Profit, page 20
2.Please quantify the factors that contributed to an increase or decrease in your gross profit.
Organic sales growth is one of the factors that accounts for increases in your gross profit.
Revise to disclose the drivers of organic sales growth.  Since cost of sales likely increase
with sales increases, discuss the relative impact of increases in cost of sales on
your gross profit margins.  If product mix contributes to changes in gross profit margin,
discuss the impact of product mix and the products that are the primary contributors.
Lastly, disclose what impact inflation had on your costs of sales and margins.  Refer to
Item 303 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 Robert Babula, Staff Accountant at (202) 551-3339, or Gus Rodriguez,
Branch Chief at (202) 551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation