SEC Comment Letter 0000000000-23-006290 to FLEXIBLE SOLUTIONS INTERNATIONAL INC (FSI) (CIK 0001069394) (FSI)
FLEXIBLE SOLUTIONS INTERNATIONAL INC (FSI) (CIK 0001069394)
Date: June 12, 2023 · CIK: 0001069394 · Accession: 0000000000-23-006290
AI Filing Summary & Sentiment
File numbers found in text: 001-31540
Letter
United States securities and exchange commission logo June 12, 2023 Daniel O'Brien President and Principal Financial Officer FLEXIBLE SOLUTIONS INTERNATIONAL INC 6001 54 Ave. Taber, Alberta, Canada T1G 1X4 Re:FLEXIBLE SOLUTIONS INTERNATIONAL INC Form 10-K filed March 31, 2023 File No. 001-31540 Dear Daniel O'Brien: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Note 10- Investments, page F-17 1.We note that during the years ended December 31, 2022 and December 31, 2021, you had sales of $12,938,735 and $7,982,281 to the Florida based LLC. Please expand your accounting policy for equity method investments on page F-12 to address the accounting implications of inventory sold by you that remain on the books of the investee at the end of the periods presented. Refer to ASC 323-10-35-7 and 35-8. Confirm that you do not recognize any intra-entity profit until the investee has sold such inventory. In closing, 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 Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551- 3355 with any questions.
FirstName LastNameDaniel O'Brien Comapany NameFLEXIBLE SOLUTIONS INTERNATIONAL INC June 12, 2023 Page 2 FirstName LastName Daniel O'Brien FLEXIBLE SOLUTIONS INTERNATIONAL INC June 12, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
June 12, 2023
Daniel O'Brien
President and Principal Financial Officer
FLEXIBLE SOLUTIONS INTERNATIONAL INC
6001 54 Ave.
Taber, Alberta, Canada T1G 1X4
Re:FLEXIBLE SOLUTIONS INTERNATIONAL INC
Form 10-K filed March 31, 2023
File No. 001-31540
Dear Daniel O'Brien:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Note 10- Investments, page F-17
1.We note that during the years ended December 31, 2022 and December 31, 2021, you had
sales of $12,938,735 and $7,982,281 to the Florida based LLC. Please expand your
accounting policy for equity method investments on page F-12 to address the accounting
implications of inventory sold by you that remain on the books of the investee at the end
of the periods presented. Refer to ASC 323-10-35-7 and 35-8. Confirm that you do
not recognize any intra-entity profit until the investee has sold such inventory.
In closing, 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 Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-
3355 with any questions.
FirstName LastNameDaniel O'Brien
Comapany NameFLEXIBLE SOLUTIONS INTERNATIONAL INC
June 12, 2023 Page 2
FirstName LastName
Daniel O'Brien
FLEXIBLE SOLUTIONS INTERNATIONAL INC
June 12, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services