SEC Comment Letter 0000000000-22-013303 to Citi Trends Inc (CTRN)
Citi Trends Inc
Date: Dec. 9, 2022 · CIK: 0001318484 · Accession: 0000000000-22-013303
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-51315
Letter
United States securities and exchange commission logo December 9, 2022 David N. Makuen Chief Executive Officer Citi Trends Inc 104 Coleman Boulevard Savannah, Georgia 31408 Re:Citi Trends Inc Form 10-K for the year ended December 31, 2021 Filed April 14, 2022 Form 8-K filed November 29, 2022 File No. 000-51315 Dear David N. Makuen: We have reviewed your filing 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 8-K filed November 29, 2022 Exhibit 99.1 Reconciliation of GAAP Basis Operating Results to Adjusted Non-GAAP Operating Results 1.Please reconcile your non-GAAP measures to the most directly comparable GAAP measures without presenting a non-GAAP income statement. Refer to Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. 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.
FirstName LastNameDavid N. Makuen Comapany NameCiti Trends Inc December 9, 2022 Page 2 FirstName LastName David N. Makuen Citi Trends Inc December 9, 2022 Page 2 You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker at (202) 551- 3769 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 9, 2022
David N. Makuen
Chief Executive Officer
Citi Trends Inc
104 Coleman Boulevard
Savannah, Georgia 31408
Re:Citi Trends Inc
Form 10-K for the year ended December 31, 2021
Filed April 14, 2022
Form 8-K filed November 29, 2022
File No. 000-51315
Dear David N. Makuen:
We have reviewed your filing 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 8-K filed November 29, 2022
Exhibit 99.1
Reconciliation of GAAP Basis Operating Results to Adjusted Non-GAAP Operating Results
1.Please reconcile your non-GAAP measures to the most directly comparable GAAP
measures without presenting a non-GAAP income statement. Refer to Question 102.10 of
the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
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.
FirstName LastNameDavid N. Makuen
Comapany NameCiti Trends Inc
December 9, 2022 Page 2
FirstName LastName
David N. Makuen
Citi Trends Inc
December 9, 2022
Page 2
You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker at (202) 551-
3769 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services