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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

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
March 31, 2016
Author
/s/ Brian Cascio
Form
UPLOAD
Company
GRAHAM CORP (GHM) (CIK 0000716314)

Letter

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

Show Raw Text
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