SEC Comment Letter for CORE MOLDING TECHNOLOGIES INC (CMT) (CIK 0001026655) (CMT) — Apr 28, 2005
CORE MOLDING TECHNOLOGIES INC (CMT) (CIK 0001026655)
Date: April 28, 2005 · CIK: 0001026655 · Accession: 0000000000-05-020731
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Please direct replies to zip code 20549-0510
April 28, 2005
via U.S. mail and facsimile
Herman F. Dick, Jr., Chief Financial Officer
Core Molding Technologies, Inc.
800 Manor Park Drive, P.O. Box 28183
Columbus, Ohio 43228-0183
Re: Form 10-K for the fiscal year ended December 31, 2004
File No. 1-12505
Dear Mr. Dick:
We have reviewed this filing and have the following comments. If
you
disagree with a comment, we will consider your explanation as to
why
our comment is inapplicable or a revision is unnecessary. Please
be
as detailed as necessary in your explanation. In some of our
comments, we may ask you to provide us with supplemental
information
so we may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to
assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing. We look
forward to working with you in these respects. We welcome any
questions you may have about our comments or on any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-K for the Year Ended December 31, 2004
General
Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like. These revisions should be
included in your future filings.
Consolidated Statements of Cash Flows, page 22
1. Your cash flow statement should report the effect of exchange
rate changes on cash balances held in foreign currencies as a
separate part of the reconciliation of the change in cash and cash
equivalents during the period. See paragraph 25 of SFAS 95.
Note 7 - Debt and Leases, page 28
2. Disclose the components of the derivative instruments` gain
or
loss related to the hedges` ineffectiveness and the gain or loss
excluded from the assessment of hedge effectiveness. In addition,
disclose how the hedging instrument entered into on January 1,
2004
will be assessed for effectiveness. See paragraph 45(b) (1) and
28(a) of SFAS 133 for guidance.
Controls and Procedures, page 37
3. We note your Chief Executive Officer and Chief Financial
Officer
concluded the Company`s disclosure controls and procedures
"...were
effective to ensure that information required to be disclosed in
the
Company`s reports filed or submitted under the Exchange Act was
accumulated and communicated to the Company`s management... as
appropriate to allow timely decisions regarding required
disclosure."
Revise to clarify, if true, that your officers concluded that your
disclosure controls and procedures are also effective to ensure
that
information required to be disclosed by you in the reports that
you
file or submit under the Exchange Act is recorded, processed,
summarized and reported, within the time periods specified in the
Commission`s rules and forms. See Exchange Act Rule 13a-15(e).
Alternatively, your officers may conclude that the Company`s
disclosure controls and procedures are "effective" without
defining
disclosure controls and procedures.
4. Please disclose any change in internal control over financial
reporting identified in connection with your evaluation of
disclosure
controls and procedures during the fourth fiscal quarter that has
materially affected, or is reasonably likely to materially affect
your internal control over financial reporting. Alternatively,
you
may disclose that no such changes have occurred. See Item 308(c)
of
Regulation S-K.
* * * *
Please respond to these comments within 10 business days, or tell
us
when you will provide us with a response. Please provide us with
a
supplemental response letter that keys your responses to our
comments
and provides any requested supplemental information. Detailed
letters greatly facilitate our review. Please file your
supplemental
response on EDGAR as a correspondence file. Please understand
that
we may have additional comments after reviewing your responses to
our
comments.
We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require for an
informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* 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.
In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.
If you have any questions regarding these comments, please direct
them to Bret Johnson, Staff Accountant, at (202) 824-5478 or, in
his
absence, to the undersigned at (202) 824-5373.
Sincerely,
John Cash
Accounting Branch Chief
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Core Molding Technologies, Inc.
Forms 10-K
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510
DIVISION OF
CORPORATION FINANCE
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