SEC Comment Letter for NWPX Infrastructure, (NWPX) — Aug 30, 2012
NWPX Infrastructure, Inc.
Date: Aug. 30, 2012 · CIK: 0001001385 · Accession: 0000000000-12-047190
AI Filing Summary & Sentiment
Letter
August 29, 2012 Via E -mail Ms. Robin Gantt Vice President and Chief Financial Officer Northwest Pipe Company 5721 SE Columbia Way, Suite 200 Vancouver, WA 98661
RE: Northwest Pipe Company Item 4.01 Form 8 -K Filed August 24, 2012 File No. 0 -27140
Dear Ms. Gantt :
We have reviewed your filing an d 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 r espond to this letter within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts an d circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
1. Please amend the F orm 8 -K to state whether the former accountant’s reports, instead of report, on the financial statements for either of the past two years contain ed an adverse opinio n or a disclaimer of opinion or were qualified or modified as to uncertainty, audit scope, or accounting principles ; and a description of the nature of each such adverse opinion, disclaime r of opinion, modification or qualification. See Item 304(a)(1)(ii) of Regulation S -K.
2. To the extent that you make c hanges to the Form 8 -K to comply with our comments, please obtain and file an updated Exhibit 16 le tter from the former accountant stating whether the accountant agrees with the statements made in your amended Form 8 -K.
We urge all persons who are respon sible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are
Ms. Robin Gantt Northwest Pipe Company August 29, 2012 Page 2
in posse ssion of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the com pany is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments 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. You may contact me at (202) 551 -3866 with any questions.
Sincerely,
/s/ Jeffrey Gordon
Show Raw Text
August 29, 2012
Via E -mail
Ms. Robin Gantt
Vice President and Chief Financial Officer
Northwest Pipe Company
5721 SE Columbia Way, Suite 200
Vancouver, WA 98661
RE: Northwest Pipe Company
Item 4.01 Form 8 -K
Filed August 24, 2012
File No. 0 -27140
Dear Ms. Gantt :
We have reviewed your filing an d 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 r espond to this letter within five business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response. If you do not believe our comments apply to your facts an d circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
1. Please amend the F orm 8 -K to state whether the former accountant’s reports, instead
of report, on the financial statements for either of the past two years contain ed an
adverse opinio n or a disclaimer of opinion or were qualified or modified as to
uncertainty, audit scope, or accounting principles ; and a description of the nature of
each such adverse opinion, disclaime r of opinion, modification or qualification. See
Item 304(a)(1)(ii) of Regulation S -K.
2. To the extent that you make c hanges to the Form 8 -K to comply with our comments, please
obtain and file an updated Exhibit 16 le tter from the former accountant stating whether the
accountant agrees with the statements made in your amended Form 8 -K.
We urge all persons who are respon sible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
Ms. Robin Gantt
Northwest Pipe Company
August 29, 2012
Page 2
in posse ssion of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
the com pany is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments 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.
You may contact me at (202) 551 -3866 with any questions.
Sincerely,
/s/ Jeffrey Gordon
Jeffrey Gordon
Staff Accountant