SEC Comment Letter for Alto Ingredients, Inc. (ALTO) (CIK 0000778164) (ALTO) — Dec 16, 2013
Alto Ingredients, Inc. (ALTO) (CIK 0000778164)
Date: Dec. 16, 2013 · CIK: 0000778164 · Accession: 0000000000-13-068233
AI Filing Summary & Sentiment
Reasoning
Letter
December 16, 2013 Via E -mail Mr. Bryon T. McGregor Chief Financial Officer Pacific Ethanol , Inc. 400 Capitol Mall , Suite 2060 Sacramento, C A 95814
Re: Pacific Eth anol, Inc. Form 10-K for the year ended December 31, 2012 Filed April 1 , 2013 File No. 0-21467
Dear Mr. McGregor :
We have reviewed your response dated November 22 , 2013 and have the following comments.
Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. 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 prov ide in response to these comments, we may have additional comments.
Form 10 -Q for the period ended September 30, 2013
Note 12. Subsequent Events, page 22
1. We note your disclosure regarding conversions of Series B notes through November 8, 2013 , however no specific statement was made regarding the date through which you evaluated your subsequent events. Please confirm that November 8, 2013 was the date throug h which you ev aluated your subsequent events.
2. Regarding your sugar feedstock purchase on October 1, 2013, tell us if this purchase was a nonrecognized subsequent event or a recognized subsequent event and how your accounting and/or disclosure complies w ith ASC 855. In this regard, it appears as if you have recognized this purchase in your September 30, 2013 financial statements resulting in an increase in prepaid inventory and borrowings.
Mr. Bryon T. McGregor Pacific Ethanol , Inc. December 16, 2013 Page 2
You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3854 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Melissa N. Rocha
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December 16, 2013 Via E -mail Mr. Bryon T. McGregor Chief Financial Officer Pacific Ethanol , Inc. 400 Capitol Mall , Suite 2060 Sacramento, C A 95814 Re: Pacific Eth anol, Inc. Form 10-K for the year ended December 31, 2012 Filed April 1 , 2013 File No. 0-21467 Dear Mr. McGregor : We have reviewed your response dated November 22 , 2013 and have the following comments. Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. 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 prov ide in response to these comments, we may have additional comments. Form 10 -Q for the period ended September 30, 2013 Note 12. Subsequent Events, page 22 1. We note your disclosure regarding conversions of Series B notes through November 8, 2013 , however no specific statement was made regarding the date through which you evaluated your subsequent events. Please confirm that November 8, 2013 was the date throug h which you ev aluated your subsequent events. 2. Regarding your sugar feedstock purchase on October 1, 2013, tell us if this purchase was a nonrecognized subsequent event or a recognized subsequent event and how your accounting and/or disclosure complies w ith ASC 855. In this regard, it appears as if you have recognized this purchase in your September 30, 2013 financial statements resulting in an increase in prepaid inventory and borrowings. Mr. Bryon T. McGregor Pacific Ethanol , Inc. December 16, 2013 Page 2 You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3854 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Melissa N. Rocha Melissa N. Rocha Senior Assistant Chief Accountant