SEC Comment Letter for Omega Flex, Inc. (OFLX) (CIK 0001317945) (OFLX) — Jun 6, 2022
Omega Flex, Inc. (OFLX) (CIK 0001317945)
Date: June 6, 2022 · CIK: 0001317945 · Accession: 0000000000-22-006084
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File numbers found in text: 000-51372
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United States securities and exchange commission logo
June 6, 2022
Matthew F. Unger
Chief Financial Officer
Omega Flex, Inc.
451 Creamery Way
Exton, PA 19341
Re:Omega Flex, Inc.
Form 10-K for the Year Ended December 31, 2021
Filed March 14, 2022
File No. 000-51372
Dear Mr. Unger:
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 10-K for the Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
21
1.We note that your discussion in MD&A excludes disclosure of any critical accounting
estimates. Please revise to include disclosure of all critical accounting estimates as
required by Item 303 of Regulation S-K. Your disclosure should include qualitative and
quantitative information necessary to understand the estimation uncertainty and the impact
the critical accounting estimate has had or is reasonably likely to have on your financial
condition or results of operations to the extent the information is material and reasonably
available. This information should include why each critical accounting estimate is subject
to uncertainty and, to the extent the information is material and reasonably available, how
much each estimate and/or assumption has changed over the period, and the sensitivity of
the reported amount to the methods, assumptions and estimates underlying its calculation.
FirstName LastNameMatthew F. Unger
Comapany NameOmega Flex, Inc.
June 6, 2022 Page 2
FirstName LastName
Matthew F. Unger
Omega Flex, Inc.
June 6, 2022
Page 2
Financial Statements
Notes to the Consolidated Financial Statements
2. Significant Accounting Policies, page 36
2.We note from your disclosure on page 37 that a warranty is generally included with each
purchase, providing assurance that the goods comply with agreed-upon specifications, and
the cost is therefore accrued accordingly. Please revise to include the disclosures required
by ASC 460-10-50-8. This includes your policy and methodology for determining
product warranty liability and a tabular reconciliation of the changes in the warranty
liability for the reporting period.
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 Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing