SEC Comment Letter for ALBANY INTERNATIONAL (AIN) — Feb 2, 2016
ALBANY INTERNATIONAL CORP /DE/ (AIN) (CIK 0000819793)
Date: Feb. 2, 2016 · CIK: 0000819793 · Accession: 0000000000-16-063450
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 February 2, 2016 John B. Cozzolino Chief Financial Officer Albany International Corp. 216 Airport Drive Rochester, New Hampshire 03867
Re: Albany International Corp. Form 10-K for the Fiscal Year Ended December 31, 2014 Response Dated January 15, 2016 File No. 1-10026
Dear Mr. Cozzolino :
We have reviewed your January 15, 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 22, 2015 letter .
Form 10 -K for the Fiscal Year Ended December 31, 2014
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Consol idated Results of Operations
Gross Profit, page 24
1. We note your response to comment 1. Refer to your proposed Machine Clothing disclosure where you state gross profit was impacted by, “a $1.7 million decrease in cost of goods sold principally due to cos t savings from restructuring activities, partially offset by inflation on wages and other manufacturing costs.” Please quantify for us each of the significant underlying components that net to the $1.7 million decrease in cost of goods
John B. Cozzolino Albany International Corp. February 2, 2016 Page 2
sold you reference. In addition, tell us what comprised “other manufacturing costs.” Lastly, where a material change is attributed to two or more factors, including any offsetting factors, please consider quantifying, where practicable and material, the contribution of eac h identified factor . In this regard, we believe that quantifying offsetting factors that are driving an overall change provides investors with greater transparency. Refer to Instruction 4 to Item 303(a) of Regulation S -K, Section III.D of SEC Release No . 33-6835 and Section III.B of SEC Release No. 33 -8350.
You may conta ct Robert Babula, Staff Accountant at (202) 551-3339, if you have questions regarding the comment on the financial statements and related matters. Please contact me at (202) 551 -3737 with any other questions.
Sincerely,
/s/ Jennifer Thompson
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Mail Stop 3561 February 2, 2016 John B. Cozzolino Chief Financial Officer Albany International Corp. 216 Airport Drive Rochester, New Hampshire 03867 Re: Albany International Corp. Form 10-K for the Fiscal Year Ended December 31, 2014 Response Dated January 15, 2016 File No. 1-10026 Dear Mr. Cozzolino : We have reviewed your January 15, 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 22, 2015 letter . Form 10 -K for the Fiscal Year Ended December 31, 2014 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Consol idated Results of Operations Gross Profit, page 24 1. We note your response to comment 1. Refer to your proposed Machine Clothing disclosure where you state gross profit was impacted by, “a $1.7 million decrease in cost of goods sold principally due to cos t savings from restructuring activities, partially offset by inflation on wages and other manufacturing costs.” Please quantify for us each of the significant underlying components that net to the $1.7 million decrease in cost of goods John B. Cozzolino Albany International Corp. February 2, 2016 Page 2 sold you reference. In addition, tell us what comprised “other manufacturing costs.” Lastly, where a material change is attributed to two or more factors, including any offsetting factors, please consider quantifying, where practicable and material, the contribution of eac h identified factor . In this regard, we believe that quantifying offsetting factors that are driving an overall change provides investors with greater transparency. Refer to Instruction 4 to Item 303(a) of Regulation S -K, Section III.D of SEC Release No . 33-6835 and Section III.B of SEC Release No. 33 -8350. You may conta ct Robert Babula, Staff Accountant at (202) 551-3339, if you have questions regarding the comment on the financial statements and related matters. Please contact me at (202) 551 -3737 with any other questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief Office of Consumer Products