SEC Comment Letter for FreightCar America, Inc. (RAIL) (CIK 0001320854) (RAIL) — Oct 14, 2016
FreightCar America, Inc. (RAIL) (CIK 0001320854)
Date: Oct. 14, 2016 · CIK: 0001320854 · Accession: 0000000000-16-097040
AI Filing Summary & Sentiment
File numbers found in text: 000-51237
Letter
Mail Stop 3561 October 13 , 2016 Matthew S. Kohnke Chief Financial Officer FreightCar America, Inc. Two North Riverside Plaza, Suite 1300 Chicago, Illinois 60606
Re: FreightCar America, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed March 4 , 2016 File No. 000-51237
Dear Mr. Kohnke :
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 re spond. 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 Fiscal Year Ended December 31, 2015
Management’s Discussion and Analysis
Results of Operations, page 21
1. Please expand your discussion of gross profit and selling, general, and administrative expenses to quantify and discuss the significant cost components within these broad categories, such as product costs, product development costs, marketing costs, depreciation and amortization, compensation, and any other significant components that would enable readers to understand your business better. For example, you state SG&A increased in 2015 due to third -party sales commissions, salaries and wages, incentive compensation and legal costs, but you do not quantify these changes or provide the actual cost figures necessary to put these changes in proper context.
Matthew S. Kohnke FreightCar America, Inc. October 13 , 2016 Page 2
We remind you that t he 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 Beverly A. Singleton at (202) 551 -3328 or Claire Erlanger at (202) 551 - 3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at ( 202) 551 -3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561 October 13 , 2016 Matthew S. Kohnke Chief Financial Officer FreightCar America, Inc. Two North Riverside Plaza, Suite 1300 Chicago, Illinois 60606 Re: FreightCar America, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed March 4 , 2016 File No. 000-51237 Dear Mr. Kohnke : 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 re spond. 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 Fiscal Year Ended December 31, 2015 Management’s Discussion and Analysis Results of Operations, page 21 1. Please expand your discussion of gross profit and selling, general, and administrative expenses to quantify and discuss the significant cost components within these broad categories, such as product costs, product development costs, marketing costs, depreciation and amortization, compensation, and any other significant components that would enable readers to understand your business better. For example, you state SG&A increased in 2015 due to third -party sales commissions, salaries and wages, incentive compensation and legal costs, but you do not quantify these changes or provide the actual cost figures necessary to put these changes in proper context. Matthew S. Kohnke FreightCar America, Inc. October 13 , 2016 Page 2 We remind you that t he 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 Beverly A. Singleton at (202) 551 -3328 or Claire Erlanger at (202) 551 - 3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at ( 202) 551 -3379 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure