SEC Comment Letter for ATI INC (ATI) (CIK 0001018963) (ATI) — Sep 25, 2013
ATI INC (ATI) (CIK 0001018963)
Date: Sept. 25, 2013 · CIK: 0001018963 · Accession: 0000000000-13-052839
AI Filing Summary & Sentiment
Reasoning
Referenced dates: August 22, 2013
Letter
September 25 , 2013 Via E -mail Mr. Patrick DeCourcy Interim Chief Financial Officer Allegheny Technologies Inc orporat ed 1000 Six PPG Place Pittsburgh, PA 15222 -5479
Re: Allegheny Technologies Incorporat ed Form 10-K Filed February 28 , 2013 File No. 1-12001
Dear Mr. DeCourcy :
We have re ad your response dated September 6, 2013 and have the following comment s.
Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment s apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you prov ide in response to these comment s, we may have additional comments.
Form 10 -Q for the period ended June 30, 2013
Note 11. Financial Information for Subsidiary and Guarantor Parent, page 16
1. We have read your response to comment 1 in our letter dated August 22, 2013. You have indicated that all lending and repayment activities to and from the parent and its subsidiaries are classified as financing activities in the condensed statements of cash flows. However, these lending activities appear to be inve sting activities by the entities making such loans or advances, as described in paragraphs 11 -13 of ASC 230 -10-45. Please explain or revise the presentation in future filings accordingly.
2. You have also told us that in future filings you will measure mater iality for determining separate disclosure of intercompany balances. Please quantify for us the intercompany asset and intercompany liability balances for the two quarters of 2013 and the last three years.
Mr. Patrick D eCourcy Allegheny Technologies Inc orporat ed September 25, 2013 Page 2
You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3355 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Terence O ’Brien
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September 25 , 2013 Via E -mail Mr. Patrick DeCourcy Interim Chief Financial Officer Allegheny Technologies Inc orporat ed 1000 Six PPG Place Pittsburgh, PA 15222 -5479 Re: Allegheny Technologies Incorporat ed Form 10-K Filed February 28 , 2013 File No. 1-12001 Dear Mr. DeCourcy : We have re ad your response dated September 6, 2013 and have the following comment s. Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment s apply to your facts and circumstances, please tell us why in your response. After reviewing the information you prov ide in response to these comment s, we may have additional comments. Form 10 -Q for the period ended June 30, 2013 Note 11. Financial Information for Subsidiary and Guarantor Parent, page 16 1. We have read your response to comment 1 in our letter dated August 22, 2013. You have indicated that all lending and repayment activities to and from the parent and its subsidiaries are classified as financing activities in the condensed statements of cash flows. However, these lending activities appear to be inve sting activities by the entities making such loans or advances, as described in paragraphs 11 -13 of ASC 230 -10-45. Please explain or revise the presentation in future filings accordingly. 2. You have also told us that in future filings you will measure mater iality for determining separate disclosure of intercompany balances. Please quantify for us the intercompany asset and intercompany liability balances for the two quarters of 2013 and the last three years. Mr. Patrick D eCourcy Allegheny Technologies Inc orporat ed September 25, 2013 Page 2 You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Terence O ’Brien Terence O’Brien Branch Chief