SEC Comment Letter for HEARTLAND EXPRESS INC (HTLD) (CIK 0000799233) (HTLD) — Nov 29, 2018
HEARTLAND EXPRESS INC (HTLD) (CIK 0000799233)
Date: Nov. 29, 2018 · CIK: 0000799233 · Accession: 0000000000-18-036650
AI Filing Summary & Sentiment
File numbers found in text: 000-15087
Letter
November 29, 2018 Christopher A. Strain Chief Financial Officer Heartland Express, Inc. 901 North Kansas Avenue North Liberty, Iowa 52317 Re:Heartland Express, Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 1, 2018 Form 10-Q for the Quarterly Period Ended September 30, 2018 Filed November 6, 2018 File No. 000-15087 Dear Mr. Strain: 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 10-Q for the Quarterly Period Ended September 30, 2018 Note 4. Revenue Recognition, page 9 1.We note your disclosure in Note 4 regarding your revenue recognition policies under ASC 606. Please revise to disclose the significant payment terms of your contracts with customers pursuant to ASC 606-10-50-12(b). Also, please disclose the nature and amount of any contract assets and contract liabilities along with the applicable disclosure requirements in ASC 606-10-50-8 through 10.
FirstName LastNameChristopher A. Strain Comapany NameHeartland Express, Inc. November 29, 2018 Page 2 FirstName LastName Christopher A. Strain Heartland Express, Inc. November 29, 2018 Page 2 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 Beverly Singleton at (202) 551-3328 or Claire Erlanger at (202) 551- 3301 with any questions. Sincerely, Division of Corporation Finance Office of Transportation and Leisure
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November 29, 2018
Christopher A. Strain
Chief Financial Officer
Heartland Express, Inc.
901 North Kansas Avenue
North Liberty, Iowa 52317
Re:Heartland Express, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 1, 2018
Form 10-Q for the Quarterly Period Ended September 30, 2018
Filed November 6, 2018
File No. 000-15087
Dear Mr. Strain:
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 10-Q for the Quarterly Period Ended September 30, 2018
Note 4. Revenue Recognition, page 9
1.We note your disclosure in Note 4 regarding your revenue recognition policies under ASC
606. Please revise to disclose the significant payment terms of your contracts with
customers pursuant to ASC 606-10-50-12(b). Also, please disclose the nature and amount
of any contract assets and contract liabilities along with the applicable disclosure
requirements in ASC 606-10-50-8 through 10.
FirstName LastNameChristopher A. Strain
Comapany NameHeartland Express, Inc.
November 29, 2018 Page 2
FirstName LastName
Christopher A. Strain
Heartland Express, Inc.
November 29, 2018
Page 2
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 Beverly Singleton at (202) 551-3328 or Claire Erlanger at (202) 551-
3301 with any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure