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UPLOAD Filing

COVENANT LOGISTICS GROUP, INC.
Date: May 22, 2025 · CIK: 0000928658 · Accession: 0000000000-25-005484

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File numbers found in text: 001-42192

Date
May 22, 2025
Author
Division of
Form
UPLOAD
Company
COVENANT LOGISTICS GROUP, INC.

Letter

Re: COVENANT LOGISTICS GROUP, INC. Form 10-K for the Year Ended December 31, 2024 Filed February 28, 2025 File No. 001-42192 Dear James S. Grant:

May 22, 2025

James S. Grant Chief Financial Officer COVENANT LOGISTICS GROUP, INC. 400 Birmingham Hwy. Chattanooga, Tennessee 37419

We have reviewed your filing and have the following comments.

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 not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form10-K for the Year Ended December 31, 2024 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Result of Segment Operations, page 36

1. We note from your disclosure in Note 17. Segment Information that segment operating income is your reported measure of segment profit or loss. Please explain why the operating income for each of your reportable segments reported and discussed within Management's Discussion and Analysis on page 36 is different than the segment operating income reported in Note 17 on page 77. In your response, address whether the CODM uses multiple measures of segment profit or loss and your consideration of the disclosure guidance in ASC 280-10-50-28 through paragraph 50- 28C. May 22, 2025 Page 2 Item 8. Financial Statements and Supplementary Data Note 1. Summary of Significant Accounting Policies; Revenue Recognition, page

2. We note that you revised your disclosure of the revenue recognition policy for the Managed Freight reportable segment during fiscal year 2023. Managed Freight revenues are now recognized proportionally as services are provided based on a percentage of completion method using the estimated time elapsed as of the period end as compared to previously recognizing revenue upon completion of the services provided. Please respond to the following: Tell us why you changed your revenue recognition policy and support the basis for the change in the timing of revenue recognition for Managed Freight services with reference to FASB ASC 606. Explain how you considered the guidance in FASB ASC 250-10 and the related required disclosures when presenting this change in accounting policy. Item 8. Financial Statements and Supplementary Data Note 17. Segment Information, page 76

3. In future filings, please revise to present a reconciliation of the total of your reportable segments' measures of profit or loss to your consolidated income before income taxes and discontinued operations, in accordance with ASC 280-10-50-30(b).

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.

Please contact Ranjit Singh Pawar at 202-551-2702 or Shannon Buskirk at 202-551- 3717 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Energy
& Transportation

Show Raw Text
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<TEXT>
 May 22, 2025

James S. Grant
Chief Financial Officer
COVENANT LOGISTICS GROUP, INC.
400 Birmingham Hwy.
Chattanooga, Tennessee 37419

 Re: COVENANT LOGISTICS GROUP, INC.
 Form 10-K for the Year Ended December 31, 2024
 Filed February 28, 2025
 File No. 001-42192
Dear James S. Grant:

 We have reviewed your filing and have the following comments.

 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
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form10-K for the Year Ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Result of Segment Operations, page 36

1. We note from your disclosure in Note 17. Segment Information that
segment
 operating income is your reported measure of segment profit or loss.
Please explain
 why the operating income for each of your reportable segments reported
and
 discussed within Management's Discussion and Analysis on page 36 is
different than
 the segment operating income reported in Note 17 on page 77. In your
response,
 address whether the CODM uses multiple measures of segment profit or
loss and your
 consideration of the disclosure guidance in ASC 280-10-50-28 through
paragraph 50-
 28C.
 May 22, 2025
Page 2
Item 8. Financial Statements and Supplementary Data
Note 1. Summary of Significant Accounting Policies; Revenue Recognition, page
60

2. We note that you revised your disclosure of the revenue recognition
policy for the
 Managed Freight reportable segment during fiscal year 2023. Managed
Freight
 revenues are now recognized proportionally as services are provided
based on a
 percentage of completion method using the estimated time elapsed as of
the period
 end as compared to previously recognizing revenue upon completion of the
services
 provided. Please respond to the following:
 Tell us why you changed your revenue recognition policy and support
the basis
 for the change in the timing of revenue recognition for Managed
Freight services
 with reference to FASB ASC 606.
 Explain how you considered the guidance in FASB ASC 250-10 and the
related
 required disclosures when presenting this change in accounting
policy.
Item 8. Financial Statements and Supplementary Data
Note 17. Segment Information, page 76

3. In future filings, please revise to present a reconciliation of the
total of your reportable
 segments' measures of profit or loss to your consolidated income before
income taxes
 and discontinued operations, in accordance with ASC 280-10-50-30(b).

 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.

 Please contact Ranjit Singh Pawar at 202-551-2702 or Shannon Buskirk at
202-551-
3717 if you have questions regarding comments on the financial statements and
related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy
& Transportation
</TEXT>
</DOCUMENT>