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SEC Comment Letter for OLD DOMINION FREIGHT LINE, INC. (ODFL) (CIK 0000878927) (ODFL) — Jan 18, 2022

OLD DOMINION FREIGHT LINE, INC. (ODFL) (CIK 0000878927)
Date: Jan. 18, 2022 · CIK: 0000878927 · Accession: 0000000000-22-000601

AI Filing Summary & Sentiment

File numbers found in text: 000-19582

Referenced dates: September 14, 2021

Date
January 18, 2022
Author
Not clearly detected
Form
UPLOAD
Company
OLD DOMINION FREIGHT LINE, INC. (ODFL) (CIK 0000878927)

Letter

United States securities and exchange commission logo January 18, 2022 Adam Satterfield Chief Financial Officer Old Dominion Freight Line, Inc. 500 Old Dominion Way Thomasville, NC 27360 Re:Old Dominion Freight Line, Inc. Form 10-K for the Fiscal Year Ended December 31, 2020 Filed February 24, 2021 File No. 000-19582 Dear Mr. Satterfield: We have reviewed your November 5, 2021 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our October 15, 2021 letter. Form 10-K for the Fiscal Year Ended December 31, 2020 Risk Factors, page 6 1.Your response to prior comment 1 states that you comprehensively monitor the risks faced by your business, including transition risks related to climate change. Please describe the process through which you monitor risk and explain in greater detail how you determined that transition risks related to climate change are not individually material. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 2.We note your response to prior comment 2 regarding the significant physical effects of climate change on your operations and results. Consistent with comment 2 from our letter dated September 14, 2021, provide us with quantitative information supporting the

FirstName LastNameAdam Satterfield Comapany NameOld Dominion Freight Line, Inc. January 18, 2022 Page 2 FirstName LastName Adam Satterfield Old Dominion Freight Line, Inc. January 18, 2022 Page 2 statement that you have not experienced material weather-related damages to your property or operations. In addition, quantify and tell us about any weather-related impacts on the cost or availability of insurance. You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan Horowitz, Accounting Branch Chief at (202) 551-3311, if you have questions regarding the comments. Sincerely, Division of Corporation Finance Office of Energy & Transportation

Show Raw Text
United States securities and exchange commission logo
January 18, 2022
Adam Satterfield
Chief Financial Officer
Old Dominion Freight Line, Inc.
500 Old Dominion Way
Thomasville, NC 27360
Re:Old Dominion Freight Line, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed February 24, 2021
File No. 000-19582
Dear Mr. Satterfield:
            We have reviewed your November 5, 2021 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
October 15, 2021 letter.
Form 10-K for the Fiscal Year Ended December 31, 2020
Risk Factors, page 6
1.Your response to prior comment 1 states that you comprehensively monitor the risks faced
by your business, including transition risks related to climate change.  Please
describe the process through which you monitor risk and explain in greater detail how you
determined that transition risks related to climate change are not individually material.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
20
2.We note your response to prior comment 2 regarding the significant physical effects of
climate change on your operations and results.  Consistent with comment 2 from our letter
dated September 14, 2021, provide us with quantitative information supporting the

 FirstName LastNameAdam Satterfield
 Comapany NameOld Dominion Freight Line, Inc.
 January 18, 2022 Page 2
 FirstName LastName
Adam Satterfield
Old Dominion Freight Line, Inc.
January 18, 2022
Page 2
statement that you have not experienced material weather-related damages to your
property or operations.  In addition, quantify and tell us about any weather-related impacts
on the cost or availability of insurance.
            You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding the comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation