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SEC Comment Letter for ALBANY INTERNATIONAL (AIN) — Mar 22, 2010

ALBANY INTERNATIONAL CORP /DE/ (AIN) (CIK 0000819793)
Date: March 22, 2010 · CIK: 0000819793 · Accession: 0000000000-10-015615

Internal Controls Financial Reporting Regulatory Compliance

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Reasoning

File numbers found in text: 001-10026

Referenced dates: December 31, 2009, December 31, 2009

Date
March 22, 2010
Author
H. Christopher Owings Assistant Director
Form
UPLOAD
Company
ALBANY INTERNATIONAL CORP /DE/ (AIN) (CIK 0000819793)

Letter

Mail Stop 3561 March 22, 2010 By Facsimile and U.S. Mail Mr. Michael Burke Senior Vice President & Chief Financial Officer Albany International Corp. 1373 Broadway Albany, New York 12204 Re: Albany International Corp. Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2008 Filed March 2, 2009 Definitive Proxy Statement on Schedule 14A Filed April 14, 2009 Quarterly Report on Form 10-Q for the Fiscal Period Ended March 31, 2009 Filed May 8, 2009 Quarterly Report on Form 10-Q for the Fiscal Period Ended June 30, 2009 Filed August 7, 2009 Quarterly Report on Form 10-Q for the Fiscal Period Ended September 30, 2009 Filed November 6, 2009 File No. 001-10026

Dear Mr. Burke:

We have reviewed your response to ou r letter dated December 31, 2009 and have the following comments. Please feel free to ca ll us at the telephone numbers listed at the end of this letter if you have any questions. Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2008

2. Revisions to Prior Balance Sheet, page 73

1. We have reviewed your responses to comments 7, 8, and 17 in our letter dated December 31, 2009. Due to the frequency of errors identified and corrected during the periods under review, please expand on how you determined that your control deficiencies did not result in a reasonable possibility that a material misstatement of your annual or interim financial statements would not be prevented or detected on a timely basis, including a discussion of each control deficiency identified. Although several of your errors ultimately turned out to be

Mr. Michael Burke Albany International Corp. March 22, 2010 Page 2 immaterial amounts, it remains unclear if your controls would have originally prevented or detected the errors on a time ly basis had the amounts been material. In regards to your tax reconc iliation errors, we further note that you subsequently recorded an adjustment to your original error correction. Please also provide us with a complete summary of any changes you made to your accounting processes and controls as a result of iden tifying these deficiencies. Form 10-Q for the Quarterly Period Ended September 30, 2009

6. Discontinued Operations, page 11

2. We have reviewed your response to comm ent 14 in our letter dated December 31, 2009 noting that you recorded a gain on the sale of your Filtration Technologies business of $6.1 million based on your expe ctation that you would receive total consideration equal to the $40 million pa id at closing plus “additional cash amounts after the post-closing adjustment pr ocess was concluded.” Please tell us if the post-closing adjustment cash amount s represents the difference between the $40 million of cash received at closing a nd the $45 million purchase price. In addition, please clarify how you determined it was appropriate to record the uncollected amounts at closing as opposed to when received or settled.

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 comment. Please contact Yong Kim, Staff Accountant, at (202) 551-3323 or Andrew Blume, Staff Accountant, at (202) 551-3254 if you have questions regarding these comments.

Sincerely,
H. Christopher Owings Assistant Director

Show Raw Text
Mail Stop 3561         March 22, 2010  By Facsimile and U.S. Mail

 Mr. Michael Burke Senior Vice President & Chief Financial Officer

Albany International Corp. 1373 Broadway Albany, New York 12204
Re: Albany International Corp.
Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2008
Filed March 2, 2009 Definitive Proxy Statement on Schedule 14A Filed April 14, 2009 Quarterly Report on Form 10-Q for the Fiscal Period Ended March 31, 2009
Filed May 8, 2009 Quarterly Report on Form 10-Q for the Fiscal Period Ended June 30, 2009
Filed August 7, 2009 Quarterly Report on Form 10-Q for the Fiscal Period Ended September 30, 2009
Filed November 6, 2009
File No. 001-10026

Dear Mr. Burke:

We have reviewed your response to ou r letter dated December 31, 2009 and have
the following comments.  Please feel free to ca ll us at the telephone numbers listed at the
end of this letter if you have any questions.
 Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2008

2.  Revisions to Prior Balance Sheet, page 73

1. We have reviewed your responses to comments 7, 8, and 17 in our letter dated
December 31, 2009.  Due to the frequency of errors identified and corrected
during the periods under review, please expand on how you determined that your
control deficiencies did not result in a reasonable possibility that a material
misstatement of your annual or interim financial statements would not be
prevented or detected on a timely basis, including a discussion of each control
deficiency identified.  Although several of your  errors ultimately turned out to be

Mr. Michael Burke
Albany International Corp. March 22, 2010 Page 2
immaterial amounts, it remains unclear if  your controls would have originally
prevented or detected the errors on a time ly basis had the amounts been material.
In regards to your tax reconc iliation errors, we further note that you subsequently
recorded an adjustment to your original error correction.  Please also provide us
with a complete summary of any changes you made to your accounting processes and controls as a result of iden tifying these deficiencies.
Form 10-Q for the Quarterly Period Ended September 30, 2009

6.  Discontinued Operations, page 11

2. We have reviewed your response to comm ent 14 in our letter dated December 31,
2009 noting that you recorded a gain on the sale of your Filtration Technologies
business of $6.1 million based on your expe ctation that you would receive total
consideration equal to the $40 million pa id at closing plus “additional cash
amounts after the post-closing adjustment pr ocess was concluded.”  Please tell us
if the post-closing adjustment cash amount s represents the difference between the
$40 million of cash received at closing a nd the $45 million purchase price.  In
addition, please clarify how you determined it was appropriate to record the uncollected amounts at closing as opposed to when received or settled.

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 comment.
 Please contact Yong Kim, Staff Accountant,  at (202) 551-3323 or Andrew Blume,
Staff Accountant, at (202) 551-3254 if you have  questions regarding these comments.

Sincerely,

H. Christopher Owings Assistant Director