SEC Comment Letter for SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Feb 17, 2017
SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: Feb. 17, 2017 · CIK: 0001092796 · Accession: 0000000000-17-005707
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4631 February 17, 2017 Via E -mail Mr. Jeffrey D. Buchanan Chief Financial Officer American Outdoor Brands Corporation 2100 Roosevelt Avenue Springfield, Massachusetts 01104
Re: American Outdoor Brands Corporation Form 10-K for the Year Ended April 30, 2016 Filed June 16, 2016 Form 10 -Q for the Period Ended October 31 , 2016 Filed December 1, 2016 File No. 1-31552
Dear Mr. Buchanan :
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 busine ss days by providing the requested information or advis e 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 r eviewing your response to these comments, we may have additional comments.
Form 10 -Q for the Period Ended October 31, 2016
Note 11. Segment Information, page 19
1. Your disclosures on page 42 of your Form 10 -K for the year ended April 30, 2016 indica te that you determined you had two operatin g segments and correspondingly two reporting units at April 30, 2016. Your Form 8 -K filed December 1, 2016 indicates that as of January 1, 2017 you now have four operating divisions, which appear to be firearms, man ufacturing services, accessori es, and electro -optics . Please disclose the impact of these recent organizational changes on your determination of operating segments and reportable segments pursuant to ASC 280 as well as the impact on your determination of reporting units for purposes of goodwill impairment testing pursuant to
Mr. Jeffrey D. Buchanan American Outdoor Brands Corporation February 17, 2017 Page 2
ASC 350 -20. Please also ensure that you provide the disclosures required by ASC 280- 10-50-21, including if you aggregated operating segments in determining your reportable segments.
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.
If you have any questions regarding these comments, please direct them to Nudrat Salik , Staff Accountant, at (202) 551 -3692 or, in her absence, Jeanne Baker, Assistant Chief Accountant, at (202) 551 -3691 .
Sincerely,
/s/ Terence O ’Brien
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Mail Stop 4631
February 17, 2017
Via E -mail
Mr. Jeffrey D. Buchanan
Chief Financial Officer
American Outdoor Brands Corporation
2100 Roosevelt Avenue
Springfield, Massachusetts 01104
Re: American Outdoor Brands Corporation
Form 10-K for the Year Ended April 30, 2016
Filed June 16, 2016
Form 10 -Q for the Period Ended October 31 , 2016
Filed December 1, 2016
File No. 1-31552
Dear Mr. Buchanan :
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 busine ss days by providing the requested
information or advis e 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 r eviewing your response to these comments, we may have additional comments.
Form 10 -Q for the Period Ended October 31, 2016
Note 11. Segment Information, page 19
1. Your disclosures on page 42 of your Form 10 -K for the year ended April 30, 2016
indica te that you determined you had two operatin g segments and correspondingly two
reporting units at April 30, 2016. Your Form 8 -K filed December 1, 2016 indicates that
as of January 1, 2017 you now have four operating divisions, which appear to be
firearms, man ufacturing services, accessori es, and electro -optics . Please disclose the
impact of these recent organizational changes on your determination of operating
segments and reportable segments pursuant to ASC 280 as well as the impact on your
determination of reporting units for purposes of goodwill impairment testing pursuant to
Mr. Jeffrey D. Buchanan
American Outdoor Brands Corporation
February 17, 2017
Page 2
ASC 350 -20. Please also ensure that you provide the disclosures required by ASC 280-
10-50-21, including if you aggregated operating segments in determining your reportable
segments.
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.
If you have any questions regarding these comments, please direct them to Nudrat Salik ,
Staff Accountant, at (202) 551 -3692 or, in her absence, Jeanne Baker, Assistant Chief
Accountant, at (202) 551 -3691 .
Sincerely,
/s/ Terence O ’Brien
Terence O’Brie n
Accounting Branch Chief
Office of Manufacturing and Construction