SEC Comment Letter for GRAHAM CORP (GHM) (CIK 0000716314) (GHM) — Nov 14, 2008
GRAHAM CORP (GHM) (CIK 0000716314)
Date: Nov. 14, 2008 · CIK: 0000716314 · Accession: 0000000000-08-056485
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08462
Letter
Re: Graham Corporation Form 10-K for the year ended March 31, 2008 Filed June 3, 2008 File No. 001-08462 Dear Mr. Hansen:
Mail Stop 6010 November 12, 2008
VIA U.S. MAIL AND FAX (585) 343-1097
Mr. J. Ronald Hansen Vice President – Finance and Administ ration and Chief Financial Officer 20 Florence Avenue Batavia, New York 14020
We have reviewed your filings and have the following comments. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Wher e indicated, we think you should revise future filings in response to these comments. If you disa gree, we will consider y our explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter 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 requir ements 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 fr ee to call us at the telephone numbers listed at th e end of this letter.
Mr. J. Ronald Hansen Graham Corporation November 12, 2008 Page 2 Form 10-Q for the three months ended June 30, 2008
Financial Statements, page 3
Consolidated Statements of Cash Flows, page 6
1. The subtotal “total adjustments” does not appear to be contemplated under SFAS 95. Please revise future filings to remove or tell us why such subtotal is appropriate. Note 3 – Investments, page 8
2. We note your disclosure that the impact of adopting all provisions of SFAS No. 157 had no effect on our financial position, results of operations and cash flows when adopted. Please revise future filings to provide the disclosures required by paragraphs 32 – 35 and 39 or tell us why such disclosure is not required.
As appropriate, please respond to these comm ents within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides 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. We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure in the filing to be certain that the filing includes all information re quired under the Securities Exchange Act of 1934 and that they have provi ded all information investors require for an informed investment decision. Since the compa ny and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of the disclosures they have made. In connection with responding to our comme nts, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
staff comments or changes to disclosure in re sponse 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 United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the sta ff of the Division of Corporati on Finance in our review of your filing or in response to our comments on your filing.
Mr. J. Ronald Hansen Graham Corporation November 12, 2008 Page 3 You may contact Julie Sherma n, Staff Accountant, at (202) 551-3640 or me at (202) 551- 3554 if you have any questions regarding these comments. In this regard, do not hesitate to contact Martin James, Senior Assist ant Chief Accountant, at (202) 551-3671. S i n c e r e l y , A n g e l a C r a n e A c c o u n t i n g B r a n c h C h i e f
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Mail Stop 6010
November 12, 2008
VIA U.S. MAIL AND FAX (585) 343-1097
Mr. J. Ronald Hansen Vice President – Finance and Administ ration and Chief Financial Officer
20 Florence Avenue Batavia, New York 14020
Re: Graham Corporation
Form 10-K for the year ended March 31, 2008
Filed June 3, 2008 File No. 001-08462
Dear Mr. Hansen:
We have reviewed your filings and have the following comments. We have limited our
review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Wher e indicated, we think you should revise future
filings in response to these comments. If you disa gree, we will consider y our explanation as to
why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary
in your explanation. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure. Af ter 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 requir ements 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 fr ee to call us at the
telephone numbers listed at th e end of this letter.
Mr. J. Ronald Hansen
Graham Corporation
November 12, 2008 Page 2 Form 10-Q for the three months ended June 30, 2008
Financial Statements, page 3
Consolidated Statements of Cash Flows, page 6
1. The subtotal “total adjustments” does not appear to be contemplated under SFAS 95.
Please revise future filings to remove or tell us why such subtotal is appropriate.
Note 3 – Investments, page 8
2. We note your disclosure that the impact of adopting all provisions of SFAS No. 157 had
no effect on our financial position, results of operations and cash flows when adopted.
Please revise future filings to provide the disclosures required by paragraphs 32 – 35 and 39 or tell us why such disclosure is not required.
As appropriate, please respond to these comm ents within 10 business days or tell us
when you will provide us with a response. Please furnish a cover letter that keys your responses
to our comments and provides 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. We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision. Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made. In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
staff comments or changes to disclosure in re sponse 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 United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
Mr. J. Ronald Hansen
Graham Corporation November 12, 2008 Page 3
You may contact Julie Sherma n, Staff Accountant, at (202) 551-3640 or me at (202) 551-
3554 if you have any questions regarding these comments. In this regard, do not hesitate to contact Martin James, Senior Assist ant Chief Accountant, at (202) 551-3671.
S i n c e r e l y , A n g e l a C r a n e A c c o u n t i n g B r a n c h C h i e f