SEC Comment Letter 0000000000-24-002076 to GRAHAM CORP (GHM) (CIK 0000716314) (GHM)
GRAHAM CORP (GHM) (CIK 0000716314)
Date: Feb. 23, 2024 · CIK: 0000716314 · Accession: 0000000000-24-002076
AI Filing Summary & Sentiment
File numbers found in text: 001-08462
Letter
United States securities and exchange commission logo February 23, 2024 Christopher J. Thome Vice President-Finance & Chief Financial Officer Graham Corp 20 Florence Ave Batavia, NY 14020 Re:Graham Corp Form 10-K for the Year Ended March 31, 2023 Form 10-Q for the Quarter Ended December 31, 2023 File No. 001-08462 Dear Christopher J. Thome: We have reviewed your February 20, 2024 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any reference to prior comments is to our February 6, 2024 letter. Form 10-Q for the Quarterly Period Ending December 31, 2023 Managements Discussion and Analysis of Financial Condition and Results of Operations Non- GAAP Measures, page 25 1.We note from your response to prior comment 1. Considering the BN Performance Bonus plan requires continued employment at the time of such payment, and as the amounts will be paid in cash, it remains unclear how such charges are not a normal, recurring cash operating expenses. Please revise to remove these adjustments from your non-GAAP measures. Refer to Question 100.01 of the non-GAAP C&DIs.
FirstName LastNameChristopher J. Thome Comapany NameGraham Corp February 23, 2024 Page 2 FirstName LastName Christopher J. Thome Graham Corp February 23, 2024 Page 2 Please contact Megan Akst at 202-551-3407 or Kathleen Collins at 202-551-3499 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Christina McLeod
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United States securities and exchange commission logo
February 23, 2024
Christopher J. Thome
Vice President-Finance & Chief Financial Officer
Graham Corp
20 Florence Ave
Batavia, NY 14020
Re:Graham Corp
Form 10-K for the Year Ended March 31, 2023
Form 10-Q for the Quarter Ended December 31, 2023
File No. 001-08462
Dear Christopher J. Thome:
We have reviewed your February 20, 2024 response to our comment letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any reference to prior comments is to our February 6, 2024 letter.
Form 10-Q for the Quarterly Period Ending December 31, 2023
Managements Discussion and Analysis of Financial Condition and Results of Operations Non-
GAAP Measures, page 25
1.We note from your response to prior comment 1. Considering the BN Performance Bonus
plan requires continued employment at the time of such payment, and as the amounts will
be paid in cash, it remains unclear how such charges are not a normal, recurring cash
operating expenses. Please revise to remove these adjustments from your non-GAAP
measures. Refer to Question 100.01 of the non-GAAP C&DIs.
FirstName LastNameChristopher J. Thome
Comapany NameGraham Corp
February 23, 2024 Page 2
FirstName LastName
Christopher J. Thome
Graham Corp
February 23, 2024
Page 2
Please contact Megan Akst at 202-551-3407 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Christina McLeod