SEC Comment Letter for MCGRATH RENTCORP (MGRC) (CIK 0000752714) (MGRC) — Sep 11, 2007
MCGRATH RENTCORP (MGRC) (CIK 0000752714)
Date: Sept. 11, 2007 · CIK: 0000752714 · Accession: 0000000000-07-044164
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 7010 September 11, 2007 Keith E. Pratt Chief Financial Officer McGrath RentCorp 5700 Las Positas Road Livermore, CA 94551-7800
Re: McGrath RentCorp Form 10-K for Fiscal Year Ended December 31, 2006 File No. 0-13292
Dear Mr. Pratt:
We have reviewed your responses an d have the following comment. Where indicated, we think you should re vise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
FORM 10-K FOR THE FISCAL YE AR ENDED DECEMBER 31, 2006
Selected Financial Data, page 25
1. We note your proposed revisions to the non-GAAP fina ncial measure disclosures you submitted in response to prior comment 1. As you indicate in the fourth paragraph of your proposed future disclo sures to be included under Item 7, management uses this measure to furt her evaluate period -to-period operating performance. Therefore, please provide a reconciliation to both Net Income and Net Cash Provided by Operating Activities in your future filings as the measure is currently used as both a performa nce and a liquidity measure.
Keith Pratt McGrath RentCorp August 9, 2007 Page 2
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Bret Johnson at (202 ) 551-3753 or me at (202) 551-3768 if you have questions regarding our comments.
Sincerely,
John Cash
Accounting Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
September 11, 2007
Keith E. Pratt
Chief Financial Officer
McGrath RentCorp
5700 Las Positas Road
Livermore, CA 94551-7800
Re: McGrath RentCorp
Form 10-K for Fiscal Year Ended December 31, 2006
File No. 0-13292
Dear Mr. Pratt:
We have reviewed your responses an d have the following comment. Where
indicated, we think you should re vise your document in response to these comments. If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary. Please be as deta iled as necessary in your explanation. In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure. After reviewing th is information, we may raise additional
comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
FORM 10-K FOR THE FISCAL YE AR ENDED DECEMBER 31, 2006
Selected Financial Data, page 25
1. We note your proposed revisions to the non-GAAP fina ncial measure disclosures
you submitted in response to prior comment 1. As you indicate in the fourth paragraph of your proposed future disclo sures to be included under Item 7,
management uses this measure to furt her evaluate period -to-period operating
performance. Therefore, please provide a reconciliation to both Net Income and
Net Cash Provided by Operating Activities in your future filings as the measure is
currently used as both a performa nce and a liquidity measure.
Keith Pratt
McGrath RentCorp
August 9, 2007
Page 2
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please furnish a letter that keys your responses to our
comments and provides any requested information. Detailed letters greatly facilitate our
review. Please understand that we may have additional comments after reviewing your
responses to our comments.
You may contact Bret Johnson at (202 ) 551-3753 or me at (202) 551-3768 if you
have questions regarding our comments.
Sincerely,
John Cash
Accounting Branch Chief