SEC Comment Letter for DXP ENTERPRISES INC (DXPE) (CIK 0001020710) (DXPE) — Jul 22, 2015
DXP ENTERPRISES INC (DXPE) (CIK 0001020710)
Date: July 22, 2015 · CIK: 0001020710 · Accession: 0000000000-15-037877
AI Filing Summary & Sentiment
Reasoning
Referenced dates: June 11, 2015
Letter
July 22 , 2015 Via E -mail Mac McConnell Senior Vice President DXP Enterprises, Inc. 7272 Pinemont Houston, Texas 77040
Re: DXP Enterprises, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Filed March 16, 2015 Response Dated July 13, 2015 File No. 0 -21513
Dear Mr. McConnell :
We have reviewed your response 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 this letter within ten 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 and 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.
Form 10 -K for Fiscal Year Ended December 31, 2014
Financial Statements, page 38
Note 17 - Segment and Geographical Reporting, page 64
1. We note your response to prior comment 3 from our letter dated June 11, 2015. Please tell us what cons ideration you gave to including your Supply Chain Services segment revenues in your calculation of service revenues for Rule 5 -03(b)(1) of Regulation S -X reporting.
Mac McConnell DXP Enterprises, Inc. July 22, 2015 Page 2
You may contact Tracie Mariner , Staff Accountant , at (202) 551 -3744 , or Jeanne Baker, Assistant Chief Accountant, at (202) 551 -3691 if you have questions regarding comments on the financial s tatements and related matters. You may contact me at (2 02) 551 -3355 with any other questions.
Sincerely,
/s/ Terence O ’Brien
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July 22 , 2015 Via E -mail Mac McConnell Senior Vice President DXP Enterprises, Inc. 7272 Pinemont Houston, Texas 77040 Re: DXP Enterprises, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Filed March 16, 2015 Response Dated July 13, 2015 File No. 0 -21513 Dear Mr. McConnell : We have reviewed your response 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 this letter within ten 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 and 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. Form 10 -K for Fiscal Year Ended December 31, 2014 Financial Statements, page 38 Note 17 - Segment and Geographical Reporting, page 64 1. We note your response to prior comment 3 from our letter dated June 11, 2015. Please tell us what cons ideration you gave to including your Supply Chain Services segment revenues in your calculation of service revenues for Rule 5 -03(b)(1) of Regulation S -X reporting. Mac McConnell DXP Enterprises, Inc. July 22, 2015 Page 2 You may contact Tracie Mariner , Staff Accountant , at (202) 551 -3744 , or Jeanne Baker, Assistant Chief Accountant, at (202) 551 -3691 if you have questions regarding comments on the financial s tatements and related matters. You may contact me at (2 02) 551 -3355 with any other questions. Sincerely, /s/ Terence O ’Brien Terence O’Brien Branch Chief