SEC Comment Letter for NWPX Infrastructure, (NWPX) — Dec 4, 2017
NWPX Infrastructure, Inc.
Date: Dec. 4, 2017 · CIK: 0001001385 · Accession: 0000000000-17-042413
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4631 December 4, 2017 Via E -mail Ms. Robin Gantt Chief Financial Officer Northwest Pipe Company 5721 SE Columbia Way, Suite 200 Vancouver, Washington 98661
Re: Northwest Pipe Company Form 10-K for the Year Ended December 31 , 2016 Filed March 9, 2017 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 respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and ci rcumstances, 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
Item 7. Management’s Discussion and Analysis of Financial Condition an d Results of Operations, page 18
Year Ended December 31, 2016 Compared to Year Ended December 31, 2015, page 21
1. We note your disclosure that one customer accounted for 27% of total net sales in 2016. In future filings, please disclose in your business s ection the name of any customer and the relationship, if any, equal to 10 percent or more of your consolidated revenues or tell us how you concluded that the potential loss of the customer will not have an adverse effect on your business as a whole. Please refer to Item 101(c)(1)(vii) of Regulation S -K.
Ms. Robin Gantt Northwest Pipe Company December 4 , 2017 Page 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 Sergio Chinos , Staff Attorney, at (202) 551 -7844 or, in his absence, Jay Ingram , Legal Branch Chief, at (202) 551 -3397 if you have any questions regarding the legal comment . Please contact Nudrat Salik , Staff Accountant, at (202) 551 -3692 or, Al Pavot, Staff Accountant, at (202) 551 -3738 if you have questions regarding the financial statements and related matters .
Sincerely,
/s/ Terence O ’Brien
Show Raw Text
Mail Stop 4631
December 4, 2017
Via E -mail
Ms. Robin Gantt
Chief Financial Officer
Northwest Pipe Company
5721 SE Columbia Way, Suite 200
Vancouver, Washington 98661
Re: Northwest Pipe Company
Form 10-K for the Year Ended December 31 , 2016
Filed March 9, 2017
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 respond to these comments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and ci rcumstances, 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
Item 7. Management’s Discussion and Analysis of Financial Condition an d Results of
Operations, page 18
Year Ended December 31, 2016 Compared to Year Ended December 31, 2015, page 21
1. We note your disclosure that one customer accounted for 27% of total net sales in 2016.
In future filings, please disclose in your business s ection the name of any customer and
the relationship, if any, equal to 10 percent or more of your consolidated revenues or tell
us how you concluded that the potential loss of the customer will not have an adverse
effect on your business as a whole. Please refer to Item 101(c)(1)(vii) of Regulation S -K.
Ms. Robin Gantt
Northwest Pipe Company
December 4 , 2017
Page 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 Sergio Chinos , Staff Attorney, at (202) 551 -7844 or, in his absence, Jay
Ingram , Legal Branch Chief, at (202) 551 -3397 if you have any questions regarding the legal
comment . Please contact Nudrat Salik , Staff Accountant, at (202) 551 -3692 or, Al Pavot, Staff
Accountant, at (202) 551 -3738 if you have questions regarding the financial statements and
related matters .
Sincerely,
/s/ Terence O ’Brien
Terence O’Brien
Accounting Branch Chief
Office of Manufacturing and Constr uction