SEC Comment Letter for SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Feb 26, 2014
SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: Feb. 26, 2014 · CIK: 0001092796 · Accession: 0000000000-14-009634
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 12, 2014, February 4, 2014
Letter
February 26 , 2014 Via E -mail Jeffrey D. Buchanan Chief Financial Officer Smith & Wesson Holding Corporation 2100 Roosevelt Avenue Springfield, Massachusetts 01102 -2208
Re: Smith & Wesson Holding Corporation Form 10 -K for Fiscal Year Ended April 30, 2013 Filed June 25, 2013 Form 10 -Q for Fiscal Quarter Ended October 31, 2013 Filed December 10, 2013 Response dated February 21 , 2014 File No. 1-31552
Dear Mr. Buchanan :
We have reviewed your response letter dated February 21 , 2014, and have the following additional 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 this letter w ithin ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewin g the information you provide in response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended April 30, 2013
19. Commitments and Contingencies, page F -34 Litigation, page F -34
1. We note your response to comment 1 in our letter dated February 12, 2014. The concern raised in our prior comment relates to the completeness of your disclosures for loss contingencies in which it is reasonably possible a material loss in excess of accrual has been incurred. In the dra ft disclosure you provided in your letter dated February 4, 2014, you state that you are unable to estimate the range of reasonably possible losses. However, it does not appear that you have provided disclosure of the nature of the claims that you are una ble to estimate the range of reasonably possible losses in excess of accrual. Please advise and revise your draft disclosures accordingly. Please refer to ASC 450-20-50-3 – 50-5 for guidance.
Mr. Buchanan Smith & Wesson Holding Corporation February 26 , 2014 Page 2
Form 10 -Q for Fiscal Quarter Ended October 31, 2013
Item 4. Controls and Procedures, page 26
2. We note the revised disclosure you intend to include in your next Form 10 -Q which qualifies the implementation of the new ERP system as a change in your internal control over financial reporting. As previously requested, please revise your draft disclosur e to clearly state, if correct, that there were changes in your internal control over financial reporting that occurred during the second quarter of fiscal year 2014 that have materially affected, or are reasonably likely to materially affect, your interna l control over financial reporting.
You may contact Tracey Smith , Staff Accountant, at (202) 551 -3736, or in her absence, me at (202) 551 -3854 , if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Melissa N. Rocha
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February 26 , 2014 Via E -mail Jeffrey D. Buchanan Chief Financial Officer Smith & Wesson Holding Corporation 2100 Roosevelt Avenue Springfield, Massachusetts 01102 -2208 Re: Smith & Wesson Holding Corporation Form 10 -K for Fiscal Year Ended April 30, 2013 Filed June 25, 2013 Form 10 -Q for Fiscal Quarter Ended October 31, 2013 Filed December 10, 2013 Response dated February 21 , 2014 File No. 1-31552 Dear Mr. Buchanan : We have reviewed your response letter dated February 21 , 2014, and have the following additional 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 this letter w ithin ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewin g the information you provide in response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended April 30, 2013 19. Commitments and Contingencies, page F -34 Litigation, page F -34 1. We note your response to comment 1 in our letter dated February 12, 2014. The concern raised in our prior comment relates to the completeness of your disclosures for loss contingencies in which it is reasonably possible a material loss in excess of accrual has been incurred. In the dra ft disclosure you provided in your letter dated February 4, 2014, you state that you are unable to estimate the range of reasonably possible losses. However, it does not appear that you have provided disclosure of the nature of the claims that you are una ble to estimate the range of reasonably possible losses in excess of accrual. Please advise and revise your draft disclosures accordingly. Please refer to ASC 450-20-50-3 – 50-5 for guidance. Mr. Buchanan Smith & Wesson Holding Corporation February 26 , 2014 Page 2 Form 10 -Q for Fiscal Quarter Ended October 31, 2013 Item 4. Controls and Procedures, page 26 2. We note the revised disclosure you intend to include in your next Form 10 -Q which qualifies the implementation of the new ERP system as a change in your internal control over financial reporting. As previously requested, please revise your draft disclosur e to clearly state, if correct, that there were changes in your internal control over financial reporting that occurred during the second quarter of fiscal year 2014 that have materially affected, or are reasonably likely to materially affect, your interna l control over financial reporting. You may contact Tracey Smith , Staff Accountant, at (202) 551 -3736, or in her absence, me at (202) 551 -3854 , if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Melissa N. Rocha Melissa N. Rocha Senior Assistant Chief Accountant