SEC Comment Letter 0000000000-23-003708 to TREX CO INC (TREX) (CIK 0001069878) (TREX)
TREX CO INC (TREX) (CIK 0001069878)
Date: April 13, 2023 · CIK: 0001069878 · Accession: 0000000000-23-003708
AI Filing Summary & Sentiment
File numbers found in text: 001-14649
Letter
United States securities and exchange commission logo April 13, 2023 Dennis C. Schemm Chief Financial Officer Trex Company, Inc. 160 Exeter Drive Winchester, Virginia 22603-8605 Re:Trex Company, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 27, 2023 File No. 001-14649 Dear Dennis C. Schemm: We have limited our review of your filing to the financial statements and related disclosures 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 37 1.Please provide a more informative discussion and analysis of cash flows from operating activities, including changes in working capital components, for the periods presented. In doing so, explain the underlying reasons and implications of material changes between periods to provide investors with an understanding of trends and variability in cash flows. Also ensure that your disclosures are not merely a recitation of changes evident from the financial statements. For example, explain the reasons for the changes in inventories and accounts receivable from fiscal 2021 to 2022. Please refer to Item 303(a) of Regulation S- K and SEC Release No. 33-8350.
FirstName LastNameDennis C. Schemm Comapany NameTrex Company, Inc. April 13, 2023 Page 2 FirstName LastName Dennis C. Schemm Trex Company, Inc. April 13, 2023 Page 2 Financial Statements Notes to Consolidated Financial Statements 17. Segment Information, page F-31 2.Please revise future filings to disclose revenues by product in accordance with ASC 280- 10-50-40. We note, for example, that you discuss major product categories on page 2, including decking and accessories, railing and fencing. 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 Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
April 13, 2023
Dennis C. Schemm
Chief Financial Officer
Trex Company, Inc.
160 Exeter Drive
Winchester, Virginia 22603-8605
Re:Trex Company, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 27, 2023
File No. 001-14649
Dear Dennis C. Schemm:
We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 37
1.Please provide a more informative discussion and analysis of cash flows from operating
activities, including changes in working capital components, for the periods presented. In
doing so, explain the underlying reasons and implications of material changes between
periods to provide investors with an understanding of trends and variability in cash flows.
Also ensure that your disclosures are not merely a recitation of changes evident from the
financial statements. For example, explain the reasons for the changes in inventories and
accounts receivable from fiscal 2021 to 2022. Please refer to Item 303(a) of Regulation S-
K and SEC Release No. 33-8350.
FirstName LastNameDennis C. Schemm
Comapany NameTrex Company, Inc.
April 13, 2023 Page 2
FirstName LastName
Dennis C. Schemm
Trex Company, Inc.
April 13, 2023
Page 2
Financial Statements
Notes to Consolidated Financial Statements
17. Segment Information, page F-31
2.Please revise future filings to disclose revenues by product in accordance with ASC 280-
10-50-40. We note, for example, that you discuss major product categories on page 2,
including decking and accessories, railing and fencing.
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 Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing