SEC Comment Letter for DXP ENTERPRISES INC (DXPE) (CIK 0001020710) (DXPE) — May 11, 2018
DXP ENTERPRISES INC (DXPE) (CIK 0001020710)
Date: May 11, 2018 · CIK: 0001020710 · Accession: 0000000000-18-014670
AI Filing Summary & Sentiment
Reasoning
Letter
May 10, 2018 Mail Stop 4631 Via E -mail Kent Yee Senior Vice President DXP Enterprises, Inc. 7272 Pinemont Drive Houston, Texas 77040
Re: DXP Enterprises, Inc. Form 10-K for Fiscal Year Ended December 3 1, 2017 Filed March 28, 2018 File No. 0-21513
Dear Mr.Yee :
We have reviewed your filing an d have the following comment s. 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 circumstances, please tell u s why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2017
Financial Statements, page 41
Audit Reports, page 42
1. We note your auditor’s reports on the financial statements and internal control over financial reporting for the fiscal year ended December 31, 2017 were not manually signed in accordance with Rule 2-02(a)(2) and Rule 2 -02(f)(2), respectively, of Regulation S -X. After you obtain signed reports from your auditors, please include them in a n amendment to your Form 10 -K. En sure that the amendment includes the entirety of Item 8 in your Form 10 -K, as well as updated officers ’ certifications, in accordance with Rule 12b -15 of the Exchange Act .
Kent Yee DXP Enterprises, Inc. May 10, 2018 Page 2
Exhibits
Exhibit 23.1
2. We note the consent from your auditor refers to its reports dated March 27, 2018 relating to your consolidated financial statements and the effectiveness of internal control over financial reporting. However, the respective reports from your auditor, included in your Form 10 -K, are both dated March 28, 2018. Please make the necessary corrections in an amendment to your Form 10 -K.
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 Tracie Mariner , Staff Accountant , at (202) 551 -3744 , or Jenn Do , Staff Accountant, at (202) 551 -3743, if you have questions regarding comments on the financial statements 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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May 10, 2018 Mail Stop 4631 Via E -mail Kent Yee Senior Vice President DXP Enterprises, Inc. 7272 Pinemont Drive Houston, Texas 77040 Re: DXP Enterprises, Inc. Form 10-K for Fiscal Year Ended December 3 1, 2017 Filed March 28, 2018 File No. 0-21513 Dear Mr.Yee : We have reviewed your filing an d have the following comment s. 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 circumstances, please tell u s why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2017 Financial Statements, page 41 Audit Reports, page 42 1. We note your auditor’s reports on the financial statements and internal control over financial reporting for the fiscal year ended December 31, 2017 were not manually signed in accordance with Rule 2-02(a)(2) and Rule 2 -02(f)(2), respectively, of Regulation S -X. After you obtain signed reports from your auditors, please include them in a n amendment to your Form 10 -K. En sure that the amendment includes the entirety of Item 8 in your Form 10 -K, as well as updated officers ’ certifications, in accordance with Rule 12b -15 of the Exchange Act . Kent Yee DXP Enterprises, Inc. May 10, 2018 Page 2 Exhibits Exhibit 23.1 2. We note the consent from your auditor refers to its reports dated March 27, 2018 relating to your consolidated financial statements and the effectiveness of internal control over financial reporting. However, the respective reports from your auditor, included in your Form 10 -K, are both dated March 28, 2018. Please make the necessary corrections in an amendment to your Form 10 -K. 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 Tracie Mariner , Staff Accountant , at (202) 551 -3744 , or Jenn Do , Staff Accountant, at (202) 551 -3743, if you have questions regarding comments on the financial statements 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 Office of Manufacturing and Construction