SEC Comment Letter for RENTECH — Jul 5, 2005
RENTECH INC /CO/ (CIK 0000868725)
Date: July 5, 2005 · CIK: 0000868725 · Accession: 0000000000-05-034175
AI Filing Summary & Sentiment
Referenced dates: June 28, 2005
Letter
Mail Stop 7010 July 5, 2005 Mr. Geoffrey S. Flagg Chief Financial Officer Rentech, Inc. 1331 17th Street, Suite 720 Denver, Colorado 80202-1557
RE: Form 10-K for the Fiscal Year Ended September 30, 2004 Forms 10-Q for the Fiscal Quarters Ended December 31, 2004 and March 31, 2005 File No. 0-19260
Dear Mr. Flagg:
We have reviewed your response letter dated June 28, and have the following additional comments. If you disagree with a comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-Q for the Quarter Ended March 31, 2005
Consolidated Statements of Cash Flows, page 7 1. We have reviewed your response to comment one. Please tell us why you have revised the operating cash flow provided by the change in accounts payable from $1,575,787 in your originally filed Form 10- Q to $544,614 in the amended Form 10-Q. Please provide us with a reconciliation of the change during the six months to the reported amounts. Tell us whether you have broken out the non-cash portion of accounts payable elsewhere in the reconciliation. If not, please cite the specific section of the relevant accounting literature supporting your exclusion of a portion of accounts payable from the period-to-period change or revise your statement of cash flows accordingly. 2. Please revise your amended Form 10-Q to label the statement of cash flows as restated and to include an explanatory note describing the restatement and the nature of the errors. Please refer to paragraphs 13, 36 & 37 of APB 20 for the correction of an error in previously issued financial statements. 3. We have reviewed your response to comment two. The detail of the Deposits and other assets line item you provided to us indicates you may have presented non-cash interest expense and other non-cash expenses as investing cash flows. Please note that the objective of SFAS 95 is to reflect cash flows by classifying cash receipts and payments based on whether they stem from operating, investing or financings activities. Expenses without an associated cash flow are generally reflected as reconciling items in the reconciliation of net income to operating cash flow. Please provide us with additional information to help us understand the appropriateness of your presentation. 4. It also appears that you have reflected debt issue costs in Deposits and other assets in 2003 and 2002. Please note that EITF 95-13 requires that such costs be reflected as financing cash flows. Please advise or revise.
* * * *
Please respond to these comments within 10 business days, or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please file your response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to Gus Rodriguez, Staff Accountant, at (202) 551-3752 or, in his absence, Scott Watkinson, Staff Accountant, at (202) 551- 3741.
Sincerely,
Rufus Decker
Branch Chief
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<TEXT>
Mail Stop 7010
July 5, 2005
Mr. Geoffrey S. Flagg
Chief Financial Officer
Rentech, Inc.
1331 17th Street, Suite 720
Denver, Colorado 80202-1557
RE: Form 10-K for the Fiscal Year Ended September 30, 2004
Forms 10-Q for the Fiscal Quarters Ended
December
31, 2004 and
March 31, 2005
File No. 0-19260
Dear Mr. Flagg:
We have reviewed your response letter dated June 28,
2005
and have the following additional comments. If you disagree with
a
comment, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-Q for the Quarter Ended March 31, 2005
Consolidated Statements of Cash Flows, page 7
1. We have reviewed your response to comment one. Please tell us
why
you have revised the operating cash flow provided by the change in
accounts payable from $1,575,787 in your originally filed Form 10-
Q
to $544,614 in the amended Form 10-Q. Please provide us with a
reconciliation of the change during the six months to the reported
amounts. Tell us whether you have broken out the non-cash portion
of
accounts payable elsewhere in the reconciliation. If not, please
cite the specific section of the relevant accounting literature
supporting your exclusion of a portion of accounts payable from
the
period-to-period change or revise your statement of cash flows
accordingly.
2. Please revise your amended Form 10-Q to label the statement of
cash flows as restated and to include an explanatory note
describing
the restatement and the nature of the errors. Please refer to
paragraphs 13, 36 & 37 of APB 20 for the correction of an error in
previously issued financial statements.
3. We have reviewed your response to comment two. The detail of
the
Deposits and other assets line item you provided to us indicates
you
may have presented non-cash interest expense and other non-cash
expenses as investing cash flows. Please note that the objective
of
SFAS 95 is to reflect cash flows by classifying cash receipts and
payments based on whether they stem from operating, investing or
financings activities. Expenses without an associated cash flow
are
generally reflected as reconciling items in the reconciliation of
net
income to operating cash flow. Please provide us with additional
information to help us understand the appropriateness of your
presentation.
4. It also appears that you have reflected debt issue costs in
Deposits and other assets in 2003 and 2002. Please note that EITF
95-13 requires that such costs be reflected as financing cash
flows.
Please advise or revise.
* * * *
Please respond to these comments within 10 business
days, or tell us when you will provide us with a response. Please
provide us with a response letter that keys your responses to our
comments and provides any requested information. Detailed letters
greatly facilitate our review. Please file your response on EDGAR
as
a correspondence file. Please understand that we may have
additional
comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please
direct them to Gus Rodriguez, Staff Accountant, at (202) 551-3752
or,
in his absence, Scott Watkinson, Staff Accountant, at (202) 551-
3741.
Sincerely,
Rufus Decker
Branch Chief
??
??
??
??
Geoffrey S. Flagg
Rentech, Inc.
July 5, 2005
Page 1 of 3
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
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