SEC Comment Letter for GRUPO SIMEC, S.A.B. de C.V. (SIM) (CIK 0000887153) (SIM) — Sep 15, 2015
GRUPO SIMEC, S.A.B. de C.V. (SIM) (CIK 0000887153)
Date: Sept. 15, 2015 · CIK: 0000887153 · Accession: 0000000000-15-045691
AI Filing Summary & Sentiment
Reasoning
Letter
September 15, 2015 Mail Stop 4631 Via E -mail Mr. Mario Moreno Cortez, Coordinator of Finance Group Simec Calzada Lázaro Cárdenas 601 Colonia La Nogalera, Guadalajara, Jalisco, México 44440
Re: Group Simec Form 20-F for the year ended December 31, 2014 Filed May 15, 2015 File No. 1 -11176
Dear Mr. Cortez :
We have reviewed your August 19, 2015 response to our comment letter and have the following comment s. 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 busine ss days by providing the requested information or advis e 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 June 23, 2015 letter .
Form 20 -F for the Year Ended December 31, 2014
Item 5. Operating and Financial Review and Prospects, page 49
Consolidated Statements of Comprehensive Income, pages 57 and 62
1. We note your responses to prior comments one and two. Please confirm that you will revise future filing to clarify the facts and circumstance that result in: material foreign exchange gains (losses) recorded in each period and material differences between statutory and effective i ncome tax rates in each period.
Mr. Mario Moreno Cortez Group Simec September 15, 2015 Page 2
USA Segment, page s 61 and 66
2. Please confirm you will revise future filings to more fully explain how you are managing negative operating trends in your USA segment. In this regard, we note that as existing sales agreeme nts expire, you will evaluate new agreements. Please disclose and discuss the typical length and pricing terms of your sales agreements. Additionally, please address the potential risks and consequences, if these trends continue.
Please contact Mindy Hooker at (202) 551 -3732, Anne McConnell at (202) 551 -3709 or me at (202) 551 -3768 with any questions.
Sincerely,
/s/ John Cash
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September 15, 2015
Mail Stop 4631
Via E -mail
Mr. Mario Moreno Cortez, Coordinator of Finance
Group Simec
Calzada Lázaro Cárdenas 601
Colonia La Nogalera, Guadalajara,
Jalisco, México 44440
Re: Group Simec
Form 20-F for the year ended December 31, 2014
Filed May 15, 2015
File No. 1 -11176
Dear Mr. Cortez :
We have reviewed your August 19, 2015 response to our comment letter and have the
following comment s. 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 busine ss days by providing the requested
information or advis e 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 June 23,
2015 letter .
Form 20 -F for the Year Ended December 31, 2014
Item 5. Operating and Financial Review and Prospects, page 49
Consolidated Statements of Comprehensive Income, pages 57 and 62
1. We note your responses to prior comments one and two. Please confirm that you will
revise future filing to clarify the facts and circumstance that result in: material foreign
exchange gains (losses) recorded in each period and material differences between
statutory and effective i ncome tax rates in each period.
Mr. Mario Moreno Cortez
Group Simec
September 15, 2015
Page 2
USA Segment, page s 61 and 66
2. Please confirm you will revise future filings to more fully explain how you are managing
negative operating trends in your USA segment. In this regard, we note that as existing
sales agreeme nts expire, you will evaluate new agreements. Please disclose and discuss
the typical length and pricing terms of your sales agreements. Additionally, please
address the potential risks and consequences, if these trends continue.
Please contact Mindy Hooker at (202) 551 -3732, Anne McConnell at (202) 551 -3709 or
me at (202) 551 -3768 with any questions.
Sincerely,
/s/ John Cash
John Cash
Branch Chief
Office of Manufacturing and
Construction
Cc: David L. Williams, Simpson, Thatcher & Bartlett LLP