SEC Comment Letter for ALBANY INTERNATIONAL (AIN) — Jan 31, 2017
ALBANY INTERNATIONAL CORP /DE/ (AIN) (CIK 0000819793)
Date: Jan. 31, 2017 · CIK: 0000819793 · Accession: 0000000000-17-003364
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 January 30, 2017 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, 2015 Response Dated January 17, 2017 File No. 1-10026
Dear Mr. Cozzolino :
We have reviewed your January 17, 2017 response to our comment letter and have the following comment . In some of our comment s, 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 p ossible 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, ou r references to prior comments are to comments in our December 20, 2016 letter .
Form 10 -K for the Fiscal Year Ended December 31, 2015
Item 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA
1. Accounting Policies
Inventories, page 53
1. We note your response to comment 2 and have the following comments:
You indicate that average cost is an element of the standard cost methodology that you use to value your inventories. Please tell us in significantly more detail how you determine the standard cost that you apply to your inventories and how average cost is an element of that standard cost. Also tell us in significantly more detail what you
John B. Cozzolino Albany International Corp. January 30, 2017 Page 2
intended to convey to your investors by previously disclosing that inventories “are valued at average cost, net of reser ves” as this appears to convey that your standard cost approximated average cost rather than that your standard cost was adjusted to approximate costs determined on the first -in, first -out basis. Refer to ASC 330 -10- 30-12.
You indicate that you regularly adjust the standard cost valuation of inventories to reflect actual cost, principally on a first -in, first -out basis. Please tell us in significantly more detail how you determine inventoriable variances, at what level you determine these variances, and why you believe your methodology for calculating and adjusting for these variances results in the presentation of inventories within your financial statements at cost as required by ASC 330 -10-30-1, 30 -9 and 30-12. Also explain to us in detail your use of the term “principally.”
You may contact Robert Babula, Staff Accountant at (202) 551 -3339, or me at (202) 551 - 3737 with any other questions.
Sincerely,
/s/ Jennifer Thompson
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Mail Stop 3561 January 30, 2017 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, 2015 Response Dated January 17, 2017 File No. 1-10026 Dear Mr. Cozzolino : We have reviewed your January 17, 2017 response to our comment letter and have the following comment . In some of our comment s, 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 p ossible 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, ou r references to prior comments are to comments in our December 20, 2016 letter . Form 10 -K for the Fiscal Year Ended December 31, 2015 Item 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA 1. Accounting Policies Inventories, page 53 1. We note your response to comment 2 and have the following comments: You indicate that average cost is an element of the standard cost methodology that you use to value your inventories. Please tell us in significantly more detail how you determine the standard cost that you apply to your inventories and how average cost is an element of that standard cost. Also tell us in significantly more detail what you John B. Cozzolino Albany International Corp. January 30, 2017 Page 2 intended to convey to your investors by previously disclosing that inventories “are valued at average cost, net of reser ves” as this appears to convey that your standard cost approximated average cost rather than that your standard cost was adjusted to approximate costs determined on the first -in, first -out basis. Refer to ASC 330 -10- 30-12. You indicate that you regularly adjust the standard cost valuation of inventories to reflect actual cost, principally on a first -in, first -out basis. Please tell us in significantly more detail how you determine inventoriable variances, at what level you determine these variances, and why you believe your methodology for calculating and adjusting for these variances results in the presentation of inventories within your financial statements at cost as required by ASC 330 -10-30-1, 30 -9 and 30-12. Also explain to us in detail your use of the term “principally.” You may contact Robert Babula, Staff Accountant at (202) 551 -3339, or me at (202) 551 - 3737 with any other questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief Office of Consumer Products