SEC Comment Letter for UFP INDUSTRIES INC (UFPI) (CIK 0000912767) (UFPI) — Jul 18, 2017
UFP INDUSTRIES INC (UFPI) (CIK 0000912767)
Date: July 18, 2017 · CIK: 0000912767 · Accession: 0000000000-17-025113
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4631 July 18 , 2017 Via E -mail Mr. Michael R. Cole Chief Financial Officer Universal Forest Products, Inc. 2801 East Beltline NE Grand Rapids, MI 49525
Re: Universal Forest Products, Inc. Form 10 -K Filed March 1 , 2017 No. 0 -22684
Dear Mr. Cole:
We have limited our review of your filing to the financial statements and related disclosures and have the following comments . We may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information, or advise us as soon as possible when you will respond. If you do n ot 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
Exhibit 13
Manageme nt’s Discussion and Analysis, page 3
Segment Reporting, page 10
1. We note from page 12 the sales allowance for the West segment increased 22% during 2016 compared to 3% during 2015. We also note from page 13 that All Other recorded income or improvemen ts in the sales allowance for both fis cal years ended 2016 and 2015. Please tell us the reason(s) for these significant changes in your allowance and revise your disclosures accordingly.
2. On page s 13 and 37 you describe iDX as “a designer, manufacture r and installer of highly customized in -store environments that are used in a range of end markets.” For each of
Mr. Michael R. Col e Universal Forest Products, Inc. July 18 , 2017 Page 2
the acquisitions included in the table on page 37, you have not included disclosure about the primary reasons for the business combinations. In this regard it is unclear how specifically the acquisition of iDX complements your core business and the synergies generated from this acquisition. Please revise disclosure to ensure you have provided all of the required disclosures in ASC 805 -10-50-2.
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 Jenn Do at (202) 551-3743 or me a t (202) 551 -3854 with any questions.
Sincerely,
/s/ Melissa N. Rocha
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Mail Stop 4631 July 18 , 2017 Via E -mail Mr. Michael R. Cole Chief Financial Officer Universal Forest Products, Inc. 2801 East Beltline NE Grand Rapids, MI 49525 Re: Universal Forest Products, Inc. Form 10 -K Filed March 1 , 2017 No. 0 -22684 Dear Mr. Cole: We have limited our review of your filing to the financial statements and related disclosures and have the following comments . We may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information, or advise us as soon as possible when you will respond. If you do n ot 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 Exhibit 13 Manageme nt’s Discussion and Analysis, page 3 Segment Reporting, page 10 1. We note from page 12 the sales allowance for the West segment increased 22% during 2016 compared to 3% during 2015. We also note from page 13 that All Other recorded income or improvemen ts in the sales allowance for both fis cal years ended 2016 and 2015. Please tell us the reason(s) for these significant changes in your allowance and revise your disclosures accordingly. 2. On page s 13 and 37 you describe iDX as “a designer, manufacture r and installer of highly customized in -store environments that are used in a range of end markets.” For each of Mr. Michael R. Col e Universal Forest Products, Inc. July 18 , 2017 Page 2 the acquisitions included in the table on page 37, you have not included disclosure about the primary reasons for the business combinations. In this regard it is unclear how specifically the acquisition of iDX complements your core business and the synergies generated from this acquisition. Please revise disclosure to ensure you have provided all of the required disclosures in ASC 805 -10-50-2. 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 Jenn Do at (202) 551-3743 or me a t (202) 551 -3854 with any questions. Sincerely, /s/ Melissa N. Rocha Melissa N. Rocha Senior Assistant Chief Accountant Office of Manufacturing and Construction