SEC Comment Letter for GRAHAM CORP (GHM) (CIK 0000716314) (GHM) — Jan 30, 2017
GRAHAM CORP (GHM) (CIK 0000716314)
Date: Jan. 30, 2017 · CIK: 0000716314 · Accession: 0000000000-17-003149
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Mail Stop 3030 January 27 , 2017 Via E -mail Mr. Jeffrey Glajch Chief Financial Officer Graham Corporation 20 Florence Avenue Batavia, New York 14020 Re: Graham Corporation Form 10-K for the Fiscal Year Ended March 31 , 2016 Filed June 1 , 2016 File No. 001 -08462 Dear Mr. Glajch : We have reviewed your filing and have the following comment . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended March 31, 2016 Report of Independent Registered Public Accounting Firm, pages 57, 58 and 62 1. In each of the reports of your Independent Registered Public Accounting Firm your auditor refers to its other reports dated May 31, 2016 although the reports are each dated June 1, 2016. Please file an amendment to include revised audit reports that correct ly indicate that the reports are each dated June 1, 2016. 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 sta ff. Jeffery Glajch Graham Corporation January 27 , 2017 Page 2 You may contact Jeanne Bennett at (202) 551 -3606 or Julie Sherman , Senior Accountant, at (202) 551 -3640 if you have any questions regarding comments on the financial statements and related matters. Please contact Tom Jones at (202) 551 -3602 or Geoffrey Kruczek, Senior Attorney, at (202) 551 -3641 with any other questions. Sincerely, /s/ Brian Cascio Brian Cascio Accounting Branch Chief Office of Electronics and Machinery