SEC Comment Letter 0000000000-23-001927 to CAE INC (CAE) (CIK 0001173382) (CAE)
CAE INC (CAE) (CIK 0001173382)
Date: Feb. 27, 2023 · CIK: 0001173382 · Accession: 0000000000-23-001927
AI Filing Summary & Sentiment
File numbers found in text: 001-31402
Letter
United States securities and exchange commission logo February 27, 2023 Sonya Branco Chief Financial Officer CAE Inc. 8585 Côte-de-Liesse Saint-Laurent, Québec, H4T 1G6 Re:CAE Inc. Form 40-F for the Fiscal Year Ended March 31, 2022 Filed June 23, 2022 File No. 001-31402 Dear Sonya Branco: 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 business days by providing the requested information or advise 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 reviewing your response to these comments, we may have additional comments. Form 40-F for the Fiscal Year Ended March 31, 2022 Management's Discussion and Analysis 4. Consolidated Results, page 22 1.You disclosed that you continue to be affected by ongoing supply chain disruptions. Please revise MD&A in future filings to more fully address whether supply chain disruptions materially affect your outlook or business goals. Quantify and disclose, to the extent possible, how your revenues, profits, and/or liquidity have been impacted, and discuss known trends or uncertainties resulting from mitigation efforts undertaken, including whether any mitigation efforts introduce new material risks, including those related to product quality, reliability, or regulatory approval.
FirstName LastNameSonya Branco Comapany NameCAE Inc. February 27, 2023 Page 2 FirstName LastName Sonya Branco CAE Inc. February 27, 2023 Page 2 Consolidated Financial Statements Note 3 - Business Combinations, page 24 2.Please provide us with the significance test calculations of Rule 1-02(w) of Regulation S- X supporting your conclusion that L3Harris Technologies Military Training business’ financial statements, pursuant to Rule 3-05 of Regulation S-X, were not required to be presented. In closing, 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. You may contact Dale Welcome at 202-551-3865 or Ernest Greene at 202-551-3733 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
February 27, 2023
Sonya Branco
Chief Financial Officer
CAE Inc.
8585 Côte-de-Liesse
Saint-Laurent, Québec, H4T 1G6
Re:CAE Inc.
Form 40-F for the Fiscal Year Ended March 31, 2022
Filed June 23, 2022
File No. 001-31402
Dear Sonya Branco:
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 business days by providing the requested
information or advise 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 reviewing your response to these comments, we may have additional comments.
Form 40-F for the Fiscal Year Ended March 31, 2022
Management's Discussion and Analysis
4. Consolidated Results, page 22
1.You disclosed that you continue to be affected by ongoing supply chain disruptions.
Please revise MD&A in future filings to more fully address whether supply chain
disruptions materially affect your outlook or business goals. Quantify and disclose, to the
extent possible, how your revenues, profits, and/or liquidity have been impacted, and
discuss known trends or uncertainties resulting from mitigation efforts undertaken,
including whether any mitigation efforts introduce new material risks, including those
related to product quality, reliability, or regulatory approval.
FirstName LastNameSonya Branco
Comapany NameCAE Inc.
February 27, 2023 Page 2
FirstName LastName
Sonya Branco
CAE Inc.
February 27, 2023
Page 2
Consolidated Financial Statements
Note 3 - Business Combinations, page 24
2.Please provide us with the significance test calculations of Rule 1-02(w) of Regulation S-
X supporting your conclusion that L3Harris Technologies Military Training business’
financial statements, pursuant to Rule 3-05 of Regulation S-X, were not required to be
presented.
In closing, 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.
You may contact Dale Welcome at 202-551-3865 or Ernest Greene at 202-551-3733 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing