SEC Comment Letter for Commercial Vehicle Group, Inc. (CVGI) (CIK 0001290900) (CVGI) — Oct 20, 2006
Commercial Vehicle Group, Inc. (CVGI) (CIK 0001290900)
Date: Oct. 20, 2006 · CIK: 0001290900 · Accession: 0000000000-06-051193
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-50890
Referenced dates: October 5, 2006
Letter
Mail Stop 3561 October 20, 2006 Via Fax & U.S. Mail Mr. Chad M. Utrup Chief Financial Officer 6530 West Campus Oval New Albany, Ohio 43054
Re: Commercial Vehicle Group, Inc. Form 10-K for the year ended December 31, 2005 Filed March 10, 2006 File No. 000-50890
Dear Mr. Utrup:
We have reviewed your response letter dated October 5, 2006 and have the following comments. Unless otherwise indi cated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us w ith information so we may better understand your disclosure. After reviewing this info rmation, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Please respond to confirm that such comments will be complied with, or, if certain of the comments are deemed inappropr iate, advise the staff of your reason. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond w ithin ten (10) business days.
Form 10-K for the year ended December 31, 2005
Note 3. Business Combinations
1. We have reviewed your response to our prior comment number 3 and the revised disclosures that you have agreed to provide in MD &A and the notes to your
Mr. Chad M. Utrup Commercial Vehicle Group, Inc. October 20, 2006 Page 2
financial statements regarding the tr eatment of your customer relationship intangibles as indefinite lived assets. Please also revise the accounting policy disclosures in the notes to the Company’s audited financial statements to include its rationale for accounting for customer relationship intangibles as indefinite lived assets. Your revised disclosures s hould be presented in a level of detail consistent with your proposed MD&A disclosures.
********
You may contact Claire Erlanger at (202) 551-3301 or me at (202) 551-3813 if you have questions regarding comments on the fi nancial statements and related matters.
Sincerely,
Linda Cvrkel
Branch Chief
Show Raw Text
Mail Stop 3561
October 20, 2006
Via Fax & U.S. Mail
Mr. Chad M. Utrup
Chief Financial Officer
6530 West Campus Oval
New Albany, Ohio 43054
Re: Commercial Vehicle Group, Inc.
Form 10-K for the year ended December 31, 2005
Filed March 10, 2006
File No. 000-50890
Dear Mr. Utrup:
We have reviewed your response letter dated October 5, 2006 and have the
following comments. Unless otherwise indi cated, we think you should revise your
document in future filings in response to these comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure. After reviewing this info rmation, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Please respond to confirm that such comments will be complied with, or, if
certain of the comments are deemed inappropr iate, advise the staff of your reason. Your
response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond w ithin ten (10) business days.
Form 10-K for the year ended December 31, 2005
Note 3. Business Combinations
1. We have reviewed your response to our prior comment number 3 and the revised
disclosures that you have agreed to provide in MD &A and the notes to your
Mr. Chad M. Utrup
Commercial Vehicle Group, Inc.
October 20, 2006 Page 2
financial statements regarding the tr eatment of your customer relationship
intangibles as indefinite lived assets. Please also revise the accounting policy
disclosures in the notes to the Company’s audited financial statements to include its rationale for accounting for customer relationship intangibles as indefinite
lived assets. Your revised disclosures s hould be presented in a level of detail
consistent with your proposed MD&A disclosures.
********
You may contact Claire Erlanger at (202) 551-3301 or me at (202) 551-3813 if
you have questions regarding comments on the fi nancial statements and related matters.
Sincerely,
Linda Cvrkel
Branch Chief