SEC Comment Letter 0000000000-23-001023 to MOTORCAR PARTS OF AMERICA INC (MPAA) (CIK 0000918251) (MPAA)
MOTORCAR PARTS OF AMERICA INC (MPAA) (CIK 0000918251)
Date: Feb. 1, 2023 · CIK: 0000918251 · Accession: 0000000000-23-001023
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File numbers found in text: 001-33861
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United States securities and exchange commission logo
February 1, 2023
David Lee
Chief Financial Officer
Motorcar Parts of America, Inc.
2929 California Street
Torrance, CA 90503
Re:Motorcar Parts of America, Inc.
Form 10-K for the Fiscal Year Ended March 31, 2022
Filed June 14, 2022
File No. 001-33861
Dear David Lee:
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 business days by providing the requested
information or advise 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 Fiscal Year Ended March 31, 2022
Note 2. Summary of Significant Accounting Policies
Segment Reporting, page F-7
1.We note your disclosure that your business comprises three separate operating
segments that "meet all the aggregation criteria and are aggregated." Please identify your
operating segments and tell us in sufficient detail how you determined your operating
segments meet all aggregation criteria described in ASC 280-10-50-11. In particular,
explain how you determined all operating segments have similar economic
characteristics.
Note 16. Income Taxes, page F-27
2.Pursuant to Rule 4-08(h) of Regulation S-X, please disclose the domestic and foreign
components of your income (loss) before income tax expense.
FirstName LastNameDavid Lee
Comapany NameMotorcar Parts of America, Inc.
February 1, 2023 Page 2
FirstName LastName
David Lee
Motorcar Parts of America, Inc.
February 1, 2023
Page 2
In closing, 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 Stephany Yang at (202) 551-3167 or Andrew Blume at (202) 551-3254
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing