SEC Comment Letter for MAGNA INTERNATIONAL (MGA) — Aug 18, 2011
MAGNA INTERNATIONAL INC
Date: Aug. 18, 2011 · CIK: 0000749098 · Accession: 0000000000-11-050125
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-11444
Referenced dates: July 26, 2011
Letter
August 18, 2011 Via E-mail
Bassem A. Shakeel Vice President Magna International Inc. 337 Magna Drive Aurora, Canada L4G 7K1 Re: Magna International Inc. Form 40-F for Fiscal Year Ended December 31, 2010 Filed on March 31, 2011 Form 6-K Filed on August 5, 2011 File No. 001-11444 Dear Mr. Shakeel: We have reviewed your response letter dated July 26, 2011 and have the following comments. In our comments, we ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter within 10 business days by confirming that you will revise your document in future filings, and pr oviding any requested information. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments. Form 40-F for Fiscal Year Ended December 31, 2010
Exhibit 2
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Results of Operations, page 17
1. We note your response to our prior comment 2. However, you have only quantified one of the four factors that are listed. Further you have only quantified $57 million of a $129 million change. A significant portion of the change (56%) is not discussed or analyzed. Please revise to quantify all factors cited. Please provide us with your proposed revised disclosure.
Bassem A. Shakeel Magna International Inc. August 18, 2011 Page 2 2. We note your response to our prior comment 3. However, you have not discussed the change in the aggregate dolla r amount of cost of goods so ld. Please revise to discuss the changes in the do llar amount of costs of goods sold. Please revise to quantify the different factors driving the change, such as the increase in commodity costs. Please provide us with your proposed revised disclosure.
Form 6-K filed on August 5, 2011
Notes to Interim Consolidated Financial Statements Note 16. Subsequent Events
3. We note that you expect to record a charge of approximately $100 million in the third quarter of 2011 in connection with the dis posal of an interior systems operation located in Germany. Please tell us what cons ideration you gave to impairment testing related to this operation as of June 30, 2011 and December 31, 2010.
You may contact Aamira Chaudhry at 202- 551-3389 if you have questions regarding comments on the financial statements and re lated matters. Please contact me at 202-551- 3380 with any other questions. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief
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August 18, 2011
Via E-mail
Bassem A. Shakeel Vice President Magna International Inc. 337 Magna Drive Aurora, Canada L4G 7K1
Re: Magna International Inc.
Form 40-F for Fiscal Year Ended December 31, 2010 Filed on March 31, 2011
Form 6-K Filed on August 5, 2011 File No. 001-11444
Dear Mr. Shakeel:
We have reviewed your response letter dated July 26, 2011 and have the following
comments. In our comments, we ask you to provi de us with information so we may better
understand your disclosure.
Please respond to this letter within 10 business days by confirming that you will
revise your document in future filings, and pr oviding any requested information. If you do
not believe our comments apply to your facts and circumstances , please tell us why in your
response.
After reviewing the information you provide in response to these comments, we may
have additional comments. Form 40-F for Fiscal Year Ended December 31, 2010
Exhibit 2
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Results of Operations, page 17
1. We note your response to our prior comment 2. However, you have only quantified
one of the four factors that are listed. Further you have only quantified $57 million of
a $129 million change. A significant portion of the change (56%) is not discussed or analyzed. Please revise to quantify all factors cited. Please provide us with your
proposed revised disclosure.
Bassem A. Shakeel
Magna International Inc. August 18, 2011 Page 2
2. We note your response to our prior comment 3. However, you have not discussed the
change in the aggregate dolla r amount of cost of goods so ld. Please revise to discuss
the changes in the do llar amount of costs of goods sold. Please revise to quantify the
different factors driving the change, such as the increase in commodity costs. Please
provide us with your proposed revised disclosure.
Form 6-K filed on August 5, 2011
Notes to Interim Consolidated Financial Statements
Note 16. Subsequent Events
3. We note that you expect to record a charge of approximately $100 million in the third
quarter of 2011 in connection with the dis posal of an interior systems operation
located in Germany. Please tell us what cons ideration you gave to impairment testing
related to this operation as of June 30, 2011 and December 31, 2010.
You may contact Aamira Chaudhry at 202- 551-3389 if you have questions regarding
comments on the financial statements and re lated matters. Please contact me at 202-551-
3380 with any other questions.
Sincerely,
/s/ Lyn Shenk Lyn Shenk
Branch Chief