SEC Comment Letter 0000000000-24-010704 to ADVANCE AUTO PARTS INC (AAP)
ADVANCE AUTO PARTS INC
Date: Sept. 20, 2024 · CIK: 0001158449 · Accession: 0000000000-24-010704
AI Filing Summary & Sentiment
File numbers found in text: 001-16797
Letter
September 20, 2024 Shane O'Kelly Chief Executive Officer Advance Auto Parts, Inc. 4200 Six Forks Road Raleigh, NC 27609 Re:Advance Auto Parts, Inc. Form 10-K for Fiscal Year Ended December 30, 2023 File No. 001-16797 Dear Shane O'Kelly: We have reviewed your filing and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended December 30, 2023 Item 11. Executive Compensation, page 29 1.From the disclosure incorporated by reference from page 31 of the Definitive Proxy Statement filed on April 8, 2024, it appears that you have not provided your disclosure about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a recovery analysis, please also include the interactive data.
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.
September 20, 2024 Page 2 Please contact Tyler Howes at 202-551-3370 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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September 20, 2024
Shane O'Kelly
Chief Executive Officer
Advance Auto Parts, Inc.
4200 Six Forks Road
Raleigh, NC 27609
Re:Advance Auto Parts, Inc.
Form 10-K for Fiscal Year Ended December 30, 2023
File No. 001-16797
Dear Shane O'Kelly:
We have reviewed your filing and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 30, 2023
Item 11. Executive Compensation, page 29
1.From the disclosure incorporated by reference from page 31 of the Definitive Proxy
Statement filed on April 8, 2024, it appears that you have not provided your disclosure
about your recovery analysis in an Interactive Data File in accordance with Rule 405 of
Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a
recovery analysis, please also include the interactive data.
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.
September 20, 2024
Page 2
Please contact Tyler Howes at 202-551-3370 or James Lopez at 202-551-3536 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Finance