SEC Comment Letter for USA Compression Partners, LP (USAC) (CIK 0001522727) (USAC) — Jul 22, 2020
USA Compression Partners, LP (USAC) (CIK 0001522727)
Date: July 22, 2020 · CIK: 0001522727 · Accession: 0000000000-20-006667
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35779
Letter
United States securities and exchange commission logo July 22, 2020 Matthew C. Liuzzi Vice President, Chief Financial Officer and Treasurer USA Compression Partners, LP 111 Congress Avenue Suite 2400 Austin, TX 78701 Re:USA Compression Partners, LP Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 18, 2020 File No. 001-35779 Dear Mr. Liuzzi: We have limited our review of your filing to the financial statements and related disclosures 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 10-K for the Fiscal Year Ended December 31, 2019 Item 6. Selected Financial Data Non-GAAP Financial Measures, page 38 1.We note your presentation of the non-GAAP measure gross operating margin. Please present a reconciliation for this non-GAAP measure in accordance with Item 10(e)(1)(i)(B) of Regulation S-K. In doing so, reconcile this measures to the most directly comparable GAAP measure of gross margin. If you do not believe gross margin that includes depreciation and amortization is the most directly comparable GAAP measure, please tell us why in your response.
FirstName LastNameMatthew C. Liuzzi Comapany NameUSA Compression Partners, LP July 22, 2020 Page 2 FirstName LastName Matthew C. Liuzzi USA Compression Partners, LP July 22, 2020 Page 2 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 Yong Kim, Staff Accountant, at (202) 551-3323 or Gus Rodriguez, Accounting Branch Chief, at (202) 551-3752 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
July 22, 2020
Matthew C. Liuzzi
Vice President, Chief Financial Officer and Treasurer
USA Compression Partners, LP
111 Congress Avenue
Suite 2400
Austin, TX 78701
Re:USA Compression Partners, LP
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 18, 2020
File No. 001-35779
Dear Mr. Liuzzi:
We have limited our review of your filing to the financial statements and related
disclosures 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 10-K for the Fiscal Year Ended December 31, 2019
Item 6. Selected Financial Data
Non-GAAP Financial Measures, page 38
1.We note your presentation of the non-GAAP measure gross operating margin. Please
present a reconciliation for this non-GAAP measure in accordance with Item
10(e)(1)(i)(B) of Regulation S-K. In doing so, reconcile this measures to the most directly
comparable GAAP measure of gross margin. If you do not believe gross margin that
includes depreciation and amortization is the most directly comparable GAAP measure,
please tell us why in your response.
FirstName LastNameMatthew C. Liuzzi
Comapany NameUSA Compression Partners, LP
July 22, 2020 Page 2
FirstName LastName
Matthew C. Liuzzi
USA Compression Partners, LP
July 22, 2020
Page 2
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 Yong Kim, Staff Accountant, at (202) 551-3323 or Gus Rodriguez,
Accounting Branch Chief, at (202) 551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation