SEC Comment Letter 0000000000-23-010190 to GENCO SHIPPING & TRADING LTD (GNK) (CIK 0001326200) (GNK)
GENCO SHIPPING & TRADING LTD (GNK) (CIK 0001326200)
Date: Sept. 14, 2023 · CIK: 0001326200 · Accession: 0000000000-23-010190
AI Filing Summary & Sentiment
File numbers found in text: 001-33393
Letter
United States securities and exchange commission logo September 14, 2023 John Wobensmith Chief Executive Officer Genco Shipping & Trading Limited 299 Park Avenue, 12th Floor New York, New York 1017 Re:Genco Shipping & Trading Limited Definitive Proxy Statement on Schedule 14A Filed April 6, 2023 File No. 001-33393 Dear John Wobensmith: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comments. Please respond to these comments by confirming that you will revise your future proxy disclosures in accordance with the topics discussed below. Definitive Proxy Statement on Schedule 14A filed April 6, 2023 Pay versus Performance, page 28 1.Please ensure that you identify each named executive officer included in the calculation of average non-PEO named executive officer compensation and the fiscal years in which such persons are included. You may provide this information in a footnote to the pay versus performance table. See Regulation S-K Item 402(v)(3). This information may not be provided by cross-reference to other sections of the proxy statement. 2.Please ensure that you revise your pay versus performance table to adjust the format of the heading "Value of Initial Fixed $ 100 Investment Based on:" to apply only to columns (f) and (g). 3.At the bottom of page 29 and top of page 30 you include identical graphs for disclosure that appears to be intended to reflect different relationships. Please ensure that the graphs reflect the intended information.
FirstName LastNameJohn Wobensmith Comapany NameGenco Shipping & Trading Limited September 14, 2023 Page 2 FirstName LastName John Wobensmith Genco Shipping & Trading Limited September 14, 2023 Page 2 Please contact Alyssa Wall at 202-551-8106 or Charlie Guidry at 202-551-3621 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program
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United States securities and exchange commission logo
September 14, 2023
John Wobensmith
Chief Executive Officer
Genco Shipping & Trading Limited
299 Park Avenue, 12th Floor
New York, New York 1017
Re:Genco Shipping & Trading Limited
Definitive Proxy Statement on Schedule 14A
Filed April 6, 2023
File No. 001-33393
Dear John Wobensmith:
We have limited our review of your most recent definitive proxy statement to those
issues we have addressed in our comments. Please respond to these comments by confirming that
you will revise your future proxy disclosures in accordance with the topics discussed below.
Definitive Proxy Statement on Schedule 14A filed April 6, 2023
Pay versus Performance, page 28
1.Please ensure that you identify each named executive officer included in the calculation of
average non-PEO named executive officer compensation and the fiscal years in which
such persons are included. You may provide this information in a footnote to the pay
versus performance table. See Regulation S-K Item 402(v)(3). This information may not
be provided by cross-reference to other sections of the proxy statement.
2.Please ensure that you revise your pay versus performance table to adjust the format of
the heading "Value of Initial Fixed $ 100 Investment Based on:" to apply only to columns
(f) and (g).
3.At the bottom of page 29 and top of page 30 you include identical graphs for disclosure
that appears to be intended to reflect different relationships. Please ensure that the graphs
reflect the intended information.
FirstName LastNameJohn Wobensmith
Comapany NameGenco Shipping & Trading Limited
September 14, 2023 Page 2
FirstName LastName
John Wobensmith
Genco Shipping & Trading Limited
September 14, 2023
Page 2
Please contact Alyssa Wall at 202-551-8106 or Charlie Guidry at 202-551-3621 with any
questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program