SEC Comment Letter 0000000000-24-002498 to CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294) (CBRL)
CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294)
Date: March 6, 2024 · CIK: 0001067294 · Accession: 0000000000-24-002498
AI Filing Summary & Sentiment
File numbers found in text: 001-25225
Letter
United States securities and exchange commission logo March 6, 2024 Craig Pommells Chief Financial Officer Cracker Barrel Old Country Store, Inc. 305 Hartmann Drive Lebanon, TN 37087-4779 Re:Cracker Barrel Old Country Store, Inc. Form 10-K for the Fiscal Year Ended July 28, 2023 Form 8-K Filed February 27, 2024 File No. 001-25225 Dear Craig Pommells: We have reviewed your filing and have the following comment(s). Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K Filed February 27, 2024 Exhibit 99.1 - Press Release issued by Cracker Barrel Old Country Store, Inc. dated February 27, Adjusted Operating Income and Earnings Per Share, page 8 1.The format of your reconciliation appears to constitute a non-GAAP income statement. Please modify your presentation in future filings or tell us why your current presentation is consistent with Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. In your response, please provide us with a sample of your proposed disclosure. 2.We note your adjustment for the non-cash amortization of the asset recognized from the gains on your sale and leaseback transactions has the effect of reversing some of the accounting effects for these transactions. Please tell us whether you consider this adjustment an individually tailored accounting principle, and if so please modify your future disclosure accordingly. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameCraig Pommells Comapany NameCracker Barrel Old Country Store, Inc. March 6, 2024 Page 2 FirstName LastName Craig Pommells Cracker Barrel Old Country Store, Inc. March 6, 2024 Page 2 3.Please tell us the basis for your adjustments for CEO transition expenses, strategic transformation initiative expenses, corporate restructuring charges and employee benefits policy change. In your response, please elaborate upon the nature of these expenses. 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. Please contact James Giugliano at 202-551-3319 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
United States securities and exchange commission logo
March 6, 2024
Craig Pommells
Chief Financial Officer
Cracker Barrel Old Country Store, Inc.
305 Hartmann Drive
Lebanon, TN 37087-4779
Re:Cracker Barrel Old Country Store, Inc.
Form 10-K for the Fiscal Year Ended July 28, 2023
Form 8-K Filed February 27, 2024
File No. 001-25225
Dear Craig Pommells:
We have reviewed your filing and have the following comment(s).
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 8-K Filed February 27, 2024
Exhibit 99.1 - Press Release issued by Cracker Barrel Old Country Store, Inc. dated February 27,
2024
Adjusted Operating Income and Earnings Per Share, page 8
1.The format of your reconciliation appears to constitute a non-GAAP income statement.
Please modify your presentation in future filings or tell us why your current presentation
is consistent with Question 102.10 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations. In your response, please provide us with a sample of your
proposed disclosure.
2.We note your adjustment for the non-cash amortization of the asset recognized from the
gains on your sale and leaseback transactions has the effect of reversing some of the
accounting effects for these transactions. Please tell us whether you consider this
adjustment an individually tailored accounting principle, and if so please modify your
future disclosure accordingly. Refer to Question 100.04 of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations.
FirstName LastNameCraig Pommells
Comapany NameCracker Barrel Old Country Store, Inc.
March 6, 2024 Page 2
FirstName LastName
Craig Pommells
Cracker Barrel Old Country Store, Inc.
March 6, 2024
Page 2
3.Please tell us the basis for your adjustments for CEO transition expenses, strategic
transformation initiative expenses, corporate restructuring charges and employee benefits
policy change. In your response, please elaborate upon the nature of these expenses.
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.
Please contact James Giugliano at 202-551-3319 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services