SEC Comment Letter for NATIONAL RV HOLDINGS INC (CIK 0000910655) — Oct 25, 2005
NATIONAL RV HOLDINGS INC (CIK 0000910655)
Date: Oct. 25, 2005 · CIK: 0000910655 · Accession: 0000000000-05-054304
AI Filing Summary & Sentiment
Letter
Zip+4 Code: 20549-0305 Via Fax & U.S. Mail Mr. Thomas J. Martini Chief Financial Officer National R.V. Holdings, Inc. 3411 N. Perris Boulevard Perris, California 92571
RE: National R.V. Holdings, Inc. (the “Company”) Form 8-K filed on October 20, 2005 File No. 1-12085
Dear Mr. Martini:
We have reviewed your filing and have the fo llowing comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapp licable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Changes in Registrant’s Certifying Accountant
1. Please file an amended Form 8-K upon the completion by PwC of services relating to the filing by the Company of its Forms 10-Q for the quarters ended March 31, 2005 and June 30, 2005.
Exhibit 16:
2. Please file a current letter from your former accountant, indicating whether or not they agree with your disclosures in the amended Form 8-K.
Other
Mr. Thomas J. Martini National R.V. Holdings, Inc. October 25, 2005 Page 2
3. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that
the company is responsible for the adequacy and accuracy of the disclosure in the filings; staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Di vision of Corporation Finance in our review of your filing or in response to our comments on your filing.
Please file your supplemental response and amendment via Edgar in response to these comments within five business days of the date of this letter. Please note that if you require longer than five business days to respond, you should contact the staff immediately to request additional time.
You may contact Effie Simpson at (202) 551-3346 or Bob Benton, at (202) 551-3804 if you have any questions.
S i n c e r e l y ,
E f f i e S i m p s o n Staff Accountant
Show Raw Text
October 25, 2005
Zip+4 Code: 20549-0305
Via Fax & U.S. Mail
Mr. Thomas J. Martini
Chief Financial Officer
National R.V. Holdings, Inc.
3411 N. Perris Boulevard
Perris, California 92571
RE: National R.V. Holdings, Inc. (the “Company”)
Form 8-K filed on October 20, 2005
File No. 1-12085
Dear Mr. Martini:
We have reviewed your filing and have the fo llowing comments. Where indicated, we think you
should revise your document in response to these comments. If you disagree, we will consider
your explanation as to why our comment is inapp licable or a revision is unnecessary. Please be
as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Changes in Registrant’s Certifying Accountant
1. Please file an amended Form 8-K upon the completion by PwC of services relating to the filing by the Company of its Forms 10-Q for the quarters ended March 31, 2005 and June 30, 2005.
Exhibit 16:
2. Please file a current letter from your former accountant, indicating whether or not they agree with your disclosures in the amended Form 8-K.
Other
Mr. Thomas J. Martini
National R.V. Holdings, Inc. October 25, 2005 Page 2
3. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that
the company is responsible for the adequacy and accuracy of the disclosure in the filings;
staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.
Please file your supplemental response and amendment via Edgar in response to these comments within five business days of the date of this letter. Please note that if you require longer than five business days to respond, you should contact the staff immediately to request additional time.
You may contact Effie Simpson at (202) 551-3346 or Bob Benton, at (202) 551-3804 if you have any questions.
S i n c e r e l y ,
E f f i e S i m p s o n
Staff Accountant