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SEC Comment Letter 0000000000-22-012503 to COMPASS MINERALS INTERNATIONAL INC (CMP) (CIK 0001227654) (CMP)

COMPASS MINERALS INTERNATIONAL INC (CMP) (CIK 0001227654)
Date: Nov. 17, 2022 · CIK: 0001227654 · Accession: 0000000000-22-012503

AI Filing Summary & Sentiment

File numbers found in text: 001-31921

Date
November 17, 2022
Author
Not clearly detected
Form
UPLOAD
Company
COMPASS MINERALS INTERNATIONAL INC (CMP) (CIK 0001227654)

Letter

United States securities and exchange commission logo November 17, 2022 Lorin Crenshaw Chief Financial Officer Compass Minerals International, Inc. 9900 West 109th Street, Suite 100 Overland Park, KS 66210 Re:Compass Minerals International, Inc. Form 10-KT for the transition period from January 1, 2021 to September 30, Filed November 30, 2021 Response letter filed October 20, 2022 File No. 001-31921 Dear Lorin Crenshaw: We have reviewed your October 20, 2022 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 28, 2022 letter. Form 10-KT for the Fiscal Year Ended September 30, 2021 Item 9A. Controls and Procedures, page 120 1.Your response to comment 3 indicates that the Company had several accounting errors in addition to the distribution variance inventory error. Please address the following:

•Tell us the nature of each error, the judgment and estimation involved for each error, and how the error was detected; •Tell us the specific nature and design of the internal control that failed with regard to each identified error; •Describe for us in detail your evaluation of the severity of the control deficiency and

FirstName LastNameLorin Crenshaw Comapany NameCompass Minerals International, Inc. November 17, 2022 Page 2 FirstName LastName Lorin Crenshaw Compass Minerals International, Inc. November 17, 2022 Page 2 how you considered whether it was “reasonably possible” that the identified control deficiency would fail to prevent or detect a material misstatement. Refer to the factors beginning on page 35 of SEC Release No. 33-8810 “Commission Guidance Regarding Management’s Report on Internal Control Over Financial Reporting Under Section 13(a) or 15(d) of the Securities Exchange Act of 1934”, and; •Tell us how you evaluated the disclosure requirements related to any significant deficiencies that were identified with regard to these additional errors, including the requirement to disclose any changes made to your disclosure controls and procedures or to your internal control over financial reporting in response to a significant deficiency or material weakness. Please refer to Question 11 of the Frequently Asked Questions for Management`s Report on Internal Control over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports located on the SEC website at https://www.sec.gov/oca/controlfaq1004htm. You may contact Robert Babula, Staff Accountant at (202) 551-3339, or Gus Rodriguez, Branch Chief at (202) 551-3752 if you have questions regarding this comment on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Energy & Transportation

Show Raw Text
United States securities and exchange commission logo
November 17, 2022
Lorin Crenshaw
Chief Financial Officer
Compass Minerals International, Inc.
9900 West 109th Street, Suite 100
Overland Park, KS 66210
Re:Compass Minerals International, Inc.
Form 10-KT for the transition period from January 1, 2021 to September 30,
2021
Filed November 30, 2021
Response letter filed October 20, 2022
File No. 001-31921
Dear Lorin Crenshaw:
            We have reviewed your October 20, 2022 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
September 28, 2022 letter.
Form 10-KT for the Fiscal Year Ended September 30, 2021
Item 9A. Controls and Procedures, page 120
1.Your response to comment 3 indicates that the Company had several accounting errors in
addition to the distribution variance inventory error.  Please address the following:

•Tell us the nature of each error, the judgment and estimation involved for each
error, and how the error was detected;
•Tell us the specific nature and design of the internal control that failed with regard to
each identified error;
•Describe for us in detail your evaluation of the severity of the control deficiency and

 FirstName LastNameLorin  Crenshaw
 Comapany NameCompass Minerals International, Inc.
 November 17, 2022 Page 2
 FirstName LastName
Lorin  Crenshaw
Compass Minerals International, Inc.
November 17, 2022
Page 2
how you considered whether it was “reasonably possible” that the identified control
deficiency would fail to prevent or detect a material misstatement.  Refer to the
factors beginning on page 35 of SEC Release No. 33-8810 “Commission Guidance
Regarding Management’s Report on Internal Control Over Financial Reporting
Under Section 13(a) or 15(d) of the Securities Exchange Act of 1934”,  and;
•Tell us how you evaluated the disclosure requirements related to any significant
deficiencies that were identified with regard to these additional errors, including the
requirement to disclose any changes made to your disclosure controls and procedures
or to your internal control over financial reporting in response to
a significant deficiency or material weakness. Please refer to Question 11 of the
Frequently Asked Questions for Management`s Report on Internal Control over
Financial Reporting and Certification of Disclosure in Exchange Act Periodic
Reports located on the SEC website at https://www.sec.gov/oca/controlfaq1004htm.
            You may contact Robert Babula, Staff Accountant at (202) 551-3339, or Gus Rodriguez,
Branch Chief at (202) 551-3752 if you have questions regarding this comment on the financial
statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation