SEC Company Response from FreightCar America, Inc. (RAIL) (CIK 0001320854) (RAIL) — Oct 26, 2016
FreightCar America, Inc. (RAIL) (CIK 0001320854)
Date: Oct. 26, 2016 · CIK: 0001320854 · Accession: 0001171843-16-012632
AI Filing Summary & Sentiment
File numbers found in text: 000-51237
Referenced dates: October 13, 2016
Letter
Via EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Transportation and Leisure FreightCar America, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed March 4, 2016 File No. 000-51237
Dear Ms. Raminpour:
On behalf of FreightCar America, Inc. (the “Company”), I am submitting this response to the comments of the staff of the Securities and Exchange Commission (the “Commission”) on the above-referenced filing as set forth in your letter dated October 13, 2016 (the “Comment Letter”).
In addition to the Company’s responses set forth herein, the Company understands that it will need to consider the staff’s comments in preparing its future filings. For your convenience, the staff’s comment is set forth below in italicized text, followed by the Company’s response.
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.
The Company notes the staff’s comment and respectfully advises the staff that, in future filings, the Company will expand the discussion of gross profit and selling, general and administrative expenses to quantify the significant cost components that are the primary drivers of the changes in the reported results of operations for the periods presented [as appropriate for the circumstances for such periods].
If you have any questions, please contact me at (312) 928-0052.
Sincerely,
/s/ MATTHEW S.
KOHNKE
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October 26, 2016
Via EDGAR
Melissa Raminpour
Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
Office of Transportation and Leisure
100 F Street N.E.
Washington, DC 20549
Re:
FreightCar America, Inc.
Form 10-K for the Fiscal Year Ended December
31, 2015
Filed March 4, 2016
File No. 000-51237
Dear Ms. Raminpour:
On behalf of FreightCar America, Inc. (the “Company”),
I am submitting this response to the comments of the staff of the Securities and Exchange Commission (the “Commission”)
on the above-referenced filing as set forth in your letter dated October 13, 2016 (the “Comment Letter”).
In addition to the Company’s responses set forth herein,
the Company understands that it will need to consider the staff’s comments in preparing its future filings. For your convenience,
the staff’s comment is set forth below in italicized text, followed by the Company’s response.
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.
The Company notes the staff’s comment and respectfully
advises the staff that, in future filings, the Company will expand the discussion of gross profit and selling, general and administrative
expenses to quantify the significant cost components that are the primary drivers of the changes in the reported results of operations
for the periods presented [as appropriate for the circumstances for such periods].
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If you have any questions, please contact me at (312) 928-0052.
Sincerely,
/s/ MATTHEW S.
KOHNKE
Matthew S. Kohnke
Vice President, Finance, Chief Financial Officer and Treasurer
FreightCar America, Inc.
Two North Riverside
Plaza, Suite 1300
Chicago, IL 60606 USA
312.928.0052
FAX 312.328.0890
www.freightcaramerica.com
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