SEC Comment Letter for TRACTOR SUPPLY (TSCO) — Dec 15, 2020
TRACTOR SUPPLY CO /DE/ (TSCO) (CIK 0000916365)
Date: Dec. 15, 2020 · CIK: 0000916365 · Accession: 0000000000-20-011964
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo December 15, 2020 Kurt Barton Chief Financial Officer and Treasurer Tractor Supply Company 5401 Virginia Way Brentwood, Tennessee 37027 Re:Tractor Supply Company Form 10-K for the Fiscal Year Ended December 28, 2019 Filed February 20, 2020 File No. 0-23314 Dear Mr. Barton: We have reviewed your filing 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 this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 28, 2019 Item 11. Executive Compensation, page 73 1.We note that earnings per diluted share is one of the metrics used in your compensation plan and that you made nearly $5.4 million in common stock repurchases in 2019. In future filings, please discuss if and how the share repurchases affected the manner in which the Compensation Committee set the relevant targets used in your compensation plan and determined whether such targets were met. 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.
FirstName LastNameKurt Barton Comapany NameTractor Supply Company December 15, 2020 Page 2 FirstName LastName Kurt Barton Tractor Supply Company December 15, 2020 Page 2 You may contact Tony Watson at (202) 551-3318 or Adam Phippen at (202) 551-3336 if you have questions regarding comments on the financial statements and related matters. Please contact Taylor Beech at (202) 551-4515 or Lilyanna Peyser at (202) 551-3222 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
United States securities and exchange commission logo
December 15, 2020
Kurt Barton
Chief Financial Officer and Treasurer
Tractor Supply Company
5401 Virginia Way
Brentwood, Tennessee 37027
Re:Tractor Supply Company
Form 10-K for the Fiscal Year Ended December 28, 2019
Filed February 20, 2020
File No. 0-23314
Dear Mr. Barton:
We have reviewed your filing 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 this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 28, 2019
Item 11. Executive Compensation, page 73
1.We note that earnings per diluted share is one of the metrics used in your compensation
plan and that you made nearly $5.4 million in common stock repurchases in 2019. In
future filings, please discuss if and how the share repurchases affected the manner in
which the Compensation Committee set the relevant targets used in your compensation
plan and determined whether such targets were met.
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.
FirstName LastNameKurt Barton
Comapany NameTractor Supply Company
December 15, 2020 Page 2
FirstName LastName
Kurt Barton
Tractor Supply Company
December 15, 2020
Page 2
You may contact Tony Watson at (202) 551-3318 or Adam Phippen at (202) 551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Taylor Beech at (202) 551-4515 or Lilyanna Peyser at (202) 551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services