SEC Comment Letter for MCGRATH RENTCORP (MGRC) (CIK 0000752714) (MGRC) — Jul 23, 2020
MCGRATH RENTCORP (MGRC) (CIK 0000752714)
Date: July 23, 2020 · CIK: 0000752714 · Accession: 0000000000-20-006707
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United States securities and exchange commission logo
July 23, 2020
Keith Pratt
Chief Financial Officer
MCGRATH RENTCORP
5700 Las Positas Road
Livermore, CA 94551-7800
Re:MCGRATH RENTCORP
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 25, 2020
Form 8-K Filed February 25, 2020
File No. 0-13292
Dear Mr. Pratt:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 8-K Filed February 25, 2020
Exhibit 99.1, page 1
1.Reference is made to your disclosure of full year 2020 expected Adjusted EBITDA. In
future filings, please present a reconciliation (by schedule or other clearly understandable
method), which shall be quantitative, to the extent available without unreasonable efforts,
of the differences between the non-GAAP financial measures disclosed with the most
directly comparable financial measure or measures calculated and presented in accordance
with GAAP. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10 of the
Division's Compliance and Disclosure Interpretations for Non-GAAP Financial Measures.
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.
FirstName LastNameKeith Pratt
Comapany NameMCGRATH RENTCORP
July 23, 2020 Page 2
FirstName LastName
Keith Pratt
MCGRATH RENTCORP
July 23, 2020
Page 2
You may contact Adam Phippen at (202) 551-3336 or Donna Di Silvio at (202) 551-
3202 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services