SEC Comment Letter for MARINE PRODUCTS CORP (MPX) (CIK 0001129155) (MPX) — Sep 6, 2016
MARINE PRODUCTS CORP (MPX) (CIK 0001129155)
Date: Sept. 6, 2016 · CIK: 0001129155 · Accession: 0000000000-16-091538
AI Filing Summary & Sentiment
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September 6, 2016 Via E -mail Mr. Ben M. Palmer Chief Financial Officer Marine Products Corporation 2801 Buford Highway, Suite 520 Atlanta, GA 30329 Re: Marine Products Corporation Schedule TO -I Filed August 26 , 2016 File No. 005 -61531 Dear Mr. Palmer : We have limited our review of the filing to those issues we have addressed in our 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 by amen ding your filing, 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 or do not believe an amendment is appropriate, please tell u s why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. General 1. Please provide the information required pursuant to General Instruction C to Schedule TO with regard to each executive officer and director of the Company , or advise . Also provide the information required under Item 1003(a) of Regulation M -A pursuant to Item 3 of Schedule TO with regard to these individuals. Source and Amount of Funds, page 22 2. We read the consolidated balance sheet included within the Form 10 -Q filed August 1, 2016 . Please advise us what financial resources constitute “working capital. ” In addition, please revise to disclose any alternative financing arrangements or alternative financing plans in the event the primary financing plan falls through. If no such arrangements exist , please revise to so state. Refer to Item 1007(b) of Regulation M -A. Mr. Ben M . Palmer Marine Products Corporation September 6, 2016 Page 2 We urge all person s who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the Company and its management are in possession of all facts relating to the Company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures it has made. In responding to our comments, please provide a written statement from t he Company acknowledging that: the Company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with res pect to the filing; and the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact Justin A. Kisner, Staff Attorney, at (202) 551 -3788, or me at (202) 551 - 3440 , if you have any questions regarding our comments. Sincerely, /s/ Nicholas P. Panos Nicholas P. Panos Senior Special Counsel Office of Mergers and Acquisitions cc: Via E -mail Robert F. Dow, Esq. Arnall Golden Gregory LLP