SEC Comment Letter 0000000000-23-010544 to RPC INC (RES)
RPC INC
Date: Sept. 25, 2023 · CIK: 0000742278 · Accession: 0000000000-23-010544
AI Filing Summary & Sentiment
File numbers found in text: 001-08726
Letter
United States securities and exchange commission logo September 25, 2023 Ben Palmer Chief Executive Officer RPC Inc. 2801 Buford Highway, Suite 300 Atlanta, Georgia 30329 Re:RPC Inc. Form 10-K for the Fiscal Year ended December 31, 2022 Filed February 27, 2023 File No, 001-08726 Dear Ben Palmer: We have limited our review of your filing to the financial statements and related disclosures 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 December 31, 2022 Financial Statements Consolidated Statements of Operations, page 31 1.We note that you appear to report an incomplete cost of revenues measure that excludes depreciation and amortization, although in the disclosures on page 55 you allocate substantially all depreciation and amortization to the Technical Services and Support Services segments. Given the nature of your business, we expect that you would need to allocate depreciation and amortization of equipment used in your revenue generating activities to cost of revenues under GAAP.
If you wish to report cost of revenues components separately you should adhere to the parenthetical labeling accommodation in SAB Topic 11:B, although under this convention it should be clear which particular line items and amounts have been excluded. Any disclosures pertaining to an incomplete cost of revenues measure should include
FirstName LastNameBen Palmer Comapany NameRPC Inc. September 25, 2023 Page 2 FirstName LastName Ben Palmer RPC Inc. September 25, 2023 Page 2 comparable discussion of the excluded amounts.
Please revise as necessary to adhere to this guidance or to include the allocable portion of depreciation and amortization in your cost of revenues measure.
In closing, 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 staff. You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or John Cannarella, Staff Accountant at (202) 551-3337 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
Show Raw Text
United States securities and exchange commission logo
September 25, 2023
Ben Palmer
Chief Executive Officer
RPC Inc.
2801 Buford Highway, Suite 300
Atlanta, Georgia 30329
Re:RPC Inc.
Form 10-K for the Fiscal Year ended December 31, 2022
Filed February 27, 2023
File No, 001-08726
Dear Ben Palmer:
We have limited our review of your filing to the financial statements and related
disclosures 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 December 31, 2022
Financial Statements
Consolidated Statements of Operations, page 31
1.We note that you appear to report an incomplete cost of revenues measure
that excludes depreciation and amortization, although in the disclosures on page 55 you
allocate substantially all depreciation and amortization to the Technical Services and
Support Services segments. Given the nature of your business, we expect that you would
need to allocate depreciation and amortization of equipment used in your revenue
generating activities to cost of revenues under GAAP.
If you wish to report cost of revenues components separately you should adhere to the
parenthetical labeling accommodation in SAB Topic 11:B, although under this
convention it should be clear which particular line items and amounts have been excluded.
Any disclosures pertaining to an incomplete cost of revenues measure should include
FirstName LastNameBen Palmer
Comapany NameRPC Inc.
September 25, 2023 Page 2
FirstName LastName
Ben Palmer
RPC Inc.
September 25, 2023
Page 2
comparable discussion of the excluded amounts.
Please revise as necessary to adhere to this guidance or to include the allocable portion of
depreciation and amortization in your cost of revenues measure.
In closing, 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 staff.
You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or John Cannarella,
Staff Accountant at (202) 551-3337 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation