SEC Comment Letter for UNIVERSAL LOGISTICS HOLDINGS, INC. (ULH) (CIK 0001308208) (ULH) — Dec 2, 2020
UNIVERSAL LOGISTICS HOLDINGS, INC. (ULH) (CIK 0001308208)
Date: Dec. 2, 2020 · CIK: 0001308208 · Accession: 0000000000-20-011549
AI Filing Summary & Sentiment
File numbers found in text: 000-51142
Letter
United States securities and exchange commission logo December 2, 2020 Jude Beres Chief Financial Officer and Treasurer UNIVERSAL LOGISTICS HOLDINGS, INC. 12755 E. Nine Mile Road Warren, Michigan 48089 Re:UNIVERSAL LOGISTICS HOLDINGS, INC. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed March 16, 2020 File No. 000-51142 Dear Mr. Beres: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the Fiscal Year Ended December 31, 2019 (19) Segment Reporting , page 68 1.Your disclosure indicates that your segment presentation “reflects the manner in which management evaluates our operating segments, including an evaluation of economic characteristics and applicable aggregation criteria.” To help us understand your presentation and how you have applied the aggregation criteria, please address the following:
•Tell us your operating segments, and explain how they have been identified;
•Tell us how your operating segments have been aggregated to produce your reportable segments; and,
•Describe for us how you have evaluated the economic characteristics and applied the aggregation criteria to arrive at your reportable segments. As part of your response,
FirstName LastNameJude Beres Comapany NameUNIVERSAL LOGISTICS HOLDINGS, INC. December 2, 2020 Page 2 FirstName LastName Jude Beres UNIVERSAL LOGISTICS HOLDINGS, INC. December 2, 2020 Page 2 provide, for each period presented, the metrics you considered as part of evaluating economic characteristics. To the extent that you did not consider target margins, as shown in your Fall 2020 Investor presentation, explain to us why you did not, and provide these metrics for each your operating segments.
Your response should include sufficient detail to demonstrate how your presentation complies with the relevant provisions of FASB ASC Topic 280, including FASB ASC paragraphs 280-10-50-1 and 280-15-50-11.
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 Robert Babula, Senior Staff Accountant at (202) 551-3339, or Gus Rodriguez, Accounting Branch Chief at (202) 551-3752 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
Show Raw Text
United States securities and exchange commission logo
December 2, 2020
Jude Beres
Chief Financial Officer and Treasurer
UNIVERSAL LOGISTICS HOLDINGS, INC.
12755 E. Nine Mile Road
Warren, Michigan 48089
Re:UNIVERSAL LOGISTICS HOLDINGS, INC.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 16, 2020
File No. 000-51142
Dear Mr. Beres:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Fiscal Year Ended December 31, 2019
(19) Segment Reporting , page 68
1.Your disclosure indicates that your segment presentation “reflects the manner in which
management evaluates our operating segments, including an evaluation of economic
characteristics and applicable aggregation criteria.” To help us understand your
presentation and how you have applied the aggregation criteria, please address the
following:
•Tell us your operating segments, and explain how they have been identified;
•Tell us how your operating segments have been aggregated to produce your
reportable segments; and,
•Describe for us how you have evaluated the economic characteristics and applied the
aggregation criteria to arrive at your reportable segments. As part of your response,
FirstName LastNameJude Beres
Comapany NameUNIVERSAL LOGISTICS HOLDINGS, INC.
December 2, 2020 Page 2
FirstName LastName
Jude Beres
UNIVERSAL LOGISTICS HOLDINGS, INC.
December 2, 2020
Page 2
provide, for each period presented, the metrics you considered as part of evaluating
economic characteristics. To the extent that you did not consider target margins, as
shown in your Fall 2020 Investor presentation, explain to us why you did not, and
provide these metrics for each your operating segments.
Your response should include sufficient detail to demonstrate how your presentation
complies with the relevant provisions of FASB ASC Topic 280, including FASB ASC
paragraphs 280-10-50-1 and 280-15-50-11.
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 Robert Babula, Senior Staff Accountant at (202) 551-3339, or Gus
Rodriguez, Accounting Branch Chief at (202) 551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation