SEC Comment Letter for CPI AEROSTRUCTURES INC (CVU) (CIK 0000889348) (CVU) — Nov 30, 2017
CPI AEROSTRUCTURES INC (CVU) (CIK 0000889348)
Date: Nov. 30, 2017 · CIK: 0000889348 · Accession: 0000000000-17-042013
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3561 November 30, 2017 Vincent Palazzolo Chief Financial Officer CPI Aerostructures, Inc. 91 Heartland Blvd Edgewood, NY 11717
Re: CPI Aerostructures, Inc. Form 10-K for the Year Ended December 31, 2016 Filed March 8, 2017 File No. 001 -11398
Dear Mr. Palazzolo :
We have limited our review of your filing to the financial statements and related disclosures 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 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.
Form 10-K for the Year Ended December 31, 2016 Filed March 8, 2017
Item 7. Management’s Discussion and Analysis of Financia l Condition and Results of Operations
Adjusted Earnings, page 23
1. On pages 23 and 24, you present a full non -GAAP income statement when reconciling non-GAAP measures to the most directly comparable GAAP measures. Please be advised it is not appropriate to present a full non -GAAP income statement for purposes of reconciling non -GAAP measures to the most directly comparable GAAP measure. Please revise and reconcile without presenting a full non -GAAP income statement . See Question 102.10 of the updated Non -GAAP Compliance and Disclosure Interpretations issued on May 17, 2016.
Vincent Palazzolo CPI Aerostructures, Inc. November 30, 2017 Page 2
Notes to Financial Statements
2. Please revise to disclose revenues from external customers for each product and service or each group of similar products and services in accordance wit h ASC 280 -10-50-40. Also, in light of your disclosure on page 3 that you provide engineering, program management, supply chain management, and MRO services, please revise your statements of operations to present revenue from products and services separate ly if the amount related to these services is over 10%. Refer to Rule 5 -03.1 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 Melissa Gilmore at (202) 551 -3777 or Claire Erlanger at (202) 551 - 3301 with any questions.
Sincerely,
/s/ Melissa Raminpour
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Mailstop 3561 November 30, 2017 Vincent Palazzolo Chief Financial Officer CPI Aerostructures, Inc. 91 Heartland Blvd Edgewood, NY 11717 Re: CPI Aerostructures, Inc. Form 10-K for the Year Ended December 31, 2016 Filed March 8, 2017 File No. 001 -11398 Dear Mr. Palazzolo : We have limited our review of your filing to the financial statements and related disclosures 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 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. Form 10-K for the Year Ended December 31, 2016 Filed March 8, 2017 Item 7. Management’s Discussion and Analysis of Financia l Condition and Results of Operations Adjusted Earnings, page 23 1. On pages 23 and 24, you present a full non -GAAP income statement when reconciling non-GAAP measures to the most directly comparable GAAP measures. Please be advised it is not appropriate to present a full non -GAAP income statement for purposes of reconciling non -GAAP measures to the most directly comparable GAAP measure. Please revise and reconcile without presenting a full non -GAAP income statement . See Question 102.10 of the updated Non -GAAP Compliance and Disclosure Interpretations issued on May 17, 2016. Vincent Palazzolo CPI Aerostructures, Inc. November 30, 2017 Page 2 Notes to Financial Statements 2. Please revise to disclose revenues from external customers for each product and service or each group of similar products and services in accordance wit h ASC 280 -10-50-40. Also, in light of your disclosure on page 3 that you provide engineering, program management, supply chain management, and MRO services, please revise your statements of operations to present revenue from products and services separate ly if the amount related to these services is over 10%. Refer to Rule 5 -03.1 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 Melissa Gilmore at (202) 551 -3777 or Claire Erlanger at (202) 551 - 3301 with any questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure