SEC Comment Letter for SpartanNash Co (SPTN) (CIK 0000877422) — Apr 8, 2020
SpartanNash Co (SPTN) (CIK 0000877422)
Date: April 8, 2020 · CIK: 0000877422 · Accession: 0000000000-20-003022
AI Filing Summary & Sentiment
Letter
April 8, 2020 Mark Shamber Chief Financial Officer SpartanNash Co 850 76th Street, S.W. Grand Rapids , Michigan 49518 Re:SpartanNash Co Form 10-K for the Fiscal Year Ended December 28, 2019 Filed February 26, 2020 File No. 0-31127 Dear Mr. Shamber: We have reviewed your filing 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-K filed February 26, 2020 General , page 1 1.Please tell us your consideration of including a table of contents which cross references the location of information required by the items of Form 10-K. Refer to General Instruction H(2) of Form 10-K. Note 4. Property and Equipment, page 53 2.Please tell us your consideration of disclosing the amount of depreciation expense for the years provided. Refer to ASC 360-10-50-1. Note 13. Income Tax, page 67 3.Please tell us your consideration of disclosing the nature of the tax credits utilized in the 2019 effective income tax rate reconciliation. Refer to ASC 740-10-50-12.
FirstName LastNameMark Shamber Comapany NameSpartanNash Co April 8, 2020 Page 2 FirstName LastName Mark Shamber SpartanNash Co April 8, 2020 Page 2 Note 17. Reporting Segment Information, page 71 4.Please tell us why depreciation and amortization totals do not agree to depreciation and amortization disclosed in the statements of cash flows. Further, please provide a reconciliation of the total of the reportable segment's depreciation and amortization expense for each segment to your consolidated depreciation and amortization expense. Refer to ASC 280-10-50-30. Item 9A. Controls and Procedures, page 74 5.Please tell us your consideration of disclosing any changes in your internal control over financial reporting that occurred during your last fiscal quarter that has materially affected, or is reasonably likely to materially affect your internal control over financial reporting. Refer to Item 308(c) of Regulation S-X. 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 Tony Watson at (202) 551-3318 or Donna Di Silvio at (202) 551- 3202 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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April 8, 2020
Mark Shamber
Chief Financial Officer
SpartanNash Co
850 76th Street, S.W.
Grand Rapids , Michigan 49518
Re:SpartanNash Co
Form 10-K for the Fiscal Year Ended December 28, 2019
Filed February 26, 2020
File No. 0-31127
Dear Mr. Shamber:
We have reviewed your filing 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-K filed February 26, 2020
General , page 1
1.Please tell us your consideration of including a table of contents which cross
references the location of information required by the items of Form 10-K. Refer to
General Instruction H(2) of Form 10-K.
Note 4. Property and Equipment, page 53
2.Please tell us your consideration of disclosing the amount of depreciation expense for the
years provided. Refer to ASC 360-10-50-1.
Note 13. Income Tax, page 67
3.Please tell us your consideration of disclosing the nature of the tax credits utilized in the
2019 effective income tax rate reconciliation. Refer to ASC 740-10-50-12.
FirstName LastNameMark Shamber
Comapany NameSpartanNash Co
April 8, 2020 Page 2
FirstName LastName
Mark Shamber
SpartanNash Co
April 8, 2020
Page 2
Note 17. Reporting Segment Information, page 71
4.Please tell us why depreciation and amortization totals do not agree to depreciation and
amortization disclosed in the statements of cash flows. Further, please provide a
reconciliation of the total of the reportable segment's depreciation and amortization
expense for each segment to your consolidated depreciation and amortization expense.
Refer to ASC 280-10-50-30.
Item 9A. Controls and Procedures, page 74
5.Please tell us your consideration of disclosing any changes in your internal control over
financial reporting that occurred during your last fiscal quarter that has materially
affected, or is reasonably likely to materially affect your internal control over financial
reporting. Refer to Item 308(c) of Regulation S-X.
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 Tony Watson at (202) 551-3318 or Donna Di Silvio at (202) 551-
3202 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services