SEC Comment Letter for TAILORED BRANDS INC (CIK 0000884217) — Jan 9, 2020
TAILORED BRANDS INC (CIK 0000884217)
Date: Jan. 9, 2020 · CIK: 0000884217 · Accession: 0000000000-20-000217
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File numbers found in text: 001-16097
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January 8, 2020
Jack Calandra
Executive Vice President, CFO and Treasurer
Tailored Brands, Inc.
6380 Rogerdale Road
Houston, TX 77072
Re:Tailored Brands, Inc.
Form 10-K for the Fiscal Year Ended February 2, 2019
Filed March 29, 2019
Form 10-Q for the Fiscal Quarter Ended November 2, 2019
Filed December 12, 2019
File No. 001-16097
Dear Mr. Calandra:
We have limited our review of your filing to the financial statements and related
disclosures 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 business days by providing the requested
information or advise 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 the comment, we may have additional comments.
Form 10-Q for the Fiscal Quarter Ended November 2, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Cash Flow Activities
Operating activities, page 50
1.You assert a portion of the $212.3 million decrease in cash provided by operating
activities in the current period was due to lower net earnings after adjusting for non-cash
items. However, net income after adjusting for non-cash items in the statement of cash
flows appears to have provided an increase to operating cash flows of $68.2 million for
the current period. Please clarify this difference for us.
Additionally, please provide a more robust analysis of the $212.3 million decrease so that
FirstName LastNameJack Calandra
Comapany NameTailored Brands, Inc.
January 8, 2020 Page 2
FirstName LastName
Jack Calandra
Tailored Brands, Inc.
January 8, 2020
Page 2
investors may have a more fulsome understanding. In so doing, discuss underlying factors
contributing to the fluctuation in each of accounts payable, accrued expenses and other
current liabilities caused by timing that you disclose as a reason for the variance. Also, it
appears the unfavorable changes in "other liabilities" and "other assets" of $143.7 million
and $27.4 million, respectively, reported on the statement of cash flows may have
contributed to the decrease but there is no mention of these in your analysis. Refer to
section IV.B.1 of SEC Release No. 33-8350 for guidance on clearly and fully explaining
changes in operating cash, and quantify all factors pursuant to section 501.04 of the
Staff’s Codification of Financial Reporting. Please provide us with a copy of your
intended revised disclosure.
In closing, 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 Robert Shapiro, Senior Staff Accountant, at (202) 551-3273 or Doug
Jones, Senior Staff Accountant, at (202) 551-3309 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services