SEC Comment Letter for GRAHAM CORP (GHM) (CIK 0000716314) (GHM) — Dec 26, 2007
GRAHAM CORP (GHM) (CIK 0000716314)
Date: Dec. 26, 2007 · CIK: 0000716314 · Accession: 0000000000-07-062293
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08462
Letter
Re: Graham Corporation Form 10-K for the Fiscal-Year ended March 31, 2007 Filed June 5, 2007 Form 10-Q for the Quarterly Period ended September 30, 2007 File No. 001-08462 Dear Mr. Hansen: We have reviewed your filing and have the following comment. We have limited our review to only your financia l statements and related disclosures and do not intend to expand our review to other portions of your documents. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549
DIVISION OF CORPORATION FINANCE Mail Stop 6010 December 26, 2007
Via U.S. Mail and Facsimile to (585) 343-1097
J. Ronald Hansen Chief Financial Officer Graham Corporation 20 Florence Avenue Batavia, NY 14020
J. Ronald Hansen Graham Corporation December 26, 2007 Page 2 Form 10-Q for the Quarterly Period ended September 30, 2007
Statement of Operations and Retained Earnings
1. We note on October 26, 2007 you declared a five for four stock split and presented this on a “pro forma basis” on the face of your statement of operations. Please revise future filing to present the stock split retroactively in your financial statements for all periods presented or tell us why your current presentation is appropriate. Refer to SAB Topic 4C for guidance.
As appropriate, please respond to this co mment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comment and pr ovides any requested informa tion. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. In connection with responding to our comments, please provide, in writing, a 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 a ny action with respect to the filing; and the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any pers on under the federal s ecurities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing. You may contact Kevin Kuhar, Staff Accountant, at (202) 551-3662 or me at (202)-3554 if you have questions regarding these comments on the financial statements and related matters. In this regard, do not hesitate to contact Martin James, Senior Assistant Chief Account ant, at (202) 551-3671. S i n c e r e l y , A n g e l a C r a n e B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 6010
December 26, 2007
Via U.S. Mail and Facsimile to (585) 343-1097
J. Ronald Hansen Chief Financial Officer Graham Corporation 20 Florence Avenue
Batavia, NY 14020
Re: Graham Corporation
Form 10-K for the Fiscal-Year ended March 31, 2007
Filed June 5, 2007 Form 10-Q for the Quarterly Period ended September 30, 2007
File No. 001-08462
Dear Mr. Hansen:
We have reviewed your filing and have the following comment. We have limited
our review to only your financia l statements and related disclosures and do not intend to
expand our review to other portions of your documents. In some of our comments, we
may ask you to provide us with information so we may better understand your disclosure.
After reviewing this information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
J. Ronald Hansen
Graham Corporation December 26, 2007 Page 2 Form 10-Q for the Quarterly Period ended September 30, 2007
Statement of Operations and Retained Earnings
1. We note on October 26, 2007 you declared a five for four stock split and
presented this on a “pro forma basis” on the face of your statement of operations.
Please revise future filing to present the stock split retroactively
in your financial
statements for all periods presented or tell us why your current presentation is
appropriate. Refer to SAB Topic 4C for guidance.
As appropriate, please respond to this co mment within 10 business days or tell us
when you will provide us with a response. Please furnish a cover letter that keys your
response to our comment and pr ovides any requested informa tion. Detailed cover letters
greatly facilitate our review. Please understand that we may have additional comments
after reviewing your responses to our comments.
In connection with responding to our comments, please provide, in writing, a 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 a ny action with respect to the filing;
and
the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Kevin Kuhar, Staff Accountant, at (202) 551-3662 or me at
(202)-3554 if you have questions regarding these comments on the financial statements
and related matters. In this regard, do not hesitate to contact Martin James, Senior Assistant Chief Account ant, at (202) 551-3671.
S i n c e r e l y , A n g e l a C r a n e B r a n c h C h i e f