Correspondence 0001193125-24-227844 from ADVANCE AUTO PARTS INC (AAP)
ADVANCE AUTO PARTS INC
Date: Sept. 27, 2024 · CIK: 0001158449 · Accession: 0001193125-24-227844
AI Filing Summary & Sentiment
File numbers found in text: 001-16797
Letter
VIA EDGAR AND U.S. MAIL Division of Corporation Finance Office of Finance Washington, DC 20549 Re: Advance Auto Parts, Inc. Form 10-K for the Fiscal Year Ended December 30, 2023 File No. 001-16797
Dear Mr. Howes:
Advance Auto Parts, Inc. (the “Company”) thanks the Staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission for its comment regarding the Company’s Annual Report on Form 10-K for the Fiscal Year Ended December 30, 2023 (the “Letter”). For your convenience of reference and review, the Company has repeated your comment as presented in the Letter in bold text, with its response provided immediately under the comment.
Form 10-K for the 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.
Response:
The Company respectfully acknowledges the Staff’s comment. The Company’s recovery analysis determined that no amounts of incentive compensation were recoverable under its policy, and the interactive data related to such conclusion was inadvertently excluded. The Company appreciates the Staff’s comment and confirms that in future filings where it has conducted a recovery analysis, the Company will include an interactive data file for its Regulation S-K Item 402(w) disclosure in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual.
If the Staff has any further questions or if we can clarify our response, please do not hesitate to call me at 984-212-2059.
Sincerely,
/s/ Ryan P. Grimsland
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CORRESP 1 filename1.htm CORRESP Ryan Grimsland Executive Vice President, Chief Financial Officer Advance Auto Parts, Inc. September 27, 2024 VIA EDGAR AND U.S. MAIL The U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance Attn: Tyler Howes 100 F Street, N.E. Washington, DC 20549 Re: Advance Auto Parts, Inc. Form 10-K for the Fiscal Year Ended December 30, 2023 File No. 001-16797 Dear Mr. Howes: Advance Auto Parts, Inc. (the “Company”) thanks the Staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission for its comment regarding the Company’s Annual Report on Form 10-K for the Fiscal Year Ended December 30, 2023 (the “Letter”). For your convenience of reference and review, the Company has repeated your comment as presented in the Letter in bold text, with its response provided immediately under the comment. Form 10-K for the 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. Response: The Company respectfully acknowledges the Staff’s comment. The Company’s recovery analysis determined that no amounts of incentive compensation were recoverable under its policy, and the interactive data related to such conclusion was inadvertently excluded. The Company appreciates the Staff’s comment and confirms that in future filings where it has conducted a recovery analysis, the Company will include an interactive data file for its Regulation S-K Item 402(w) disclosure in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. If the Staff has any further questions or if we can clarify our response, please do not hesitate to call me at 984-212-2059. Sincerely, /s/ Ryan P. Grimsland Ryan P. Grimsland Executive Vice President, Chief Financial Officer cc: James Lopez, Division of Corporation Finance Shane O’Kelly, President, Chief Executive Officer Amanda Keister, Vice President, Associate General Counsel and Assistant Corporate Secretary