SEC Comment Letter 0000000000-23-006654 to Alexander & Baldwin, Inc. (ALEX) (CIK 0001545654) (ALEX)
Alexander & Baldwin, Inc. (ALEX) (CIK 0001545654)
Date: June 22, 2023 · CIK: 0001545654 · Accession: 0000000000-23-006654
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35492
Letter
United States securities and exchange commission logo June 22, 2023 Clayton Chun Executive Vice President, Chief Financial Officer and Treasurer Alexander & Baldwin, Inc. 822 Bishop Street Post Office Box 3440 Honolulu, Hawaii 96801 Re:Alexander & Baldwin, Inc. Form 10-K for the year ended December 31, 2022 File No. 001-35492 Dear Clayton Chun: 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 year ended December 31, 2022 Critical Accounting Estimates, page 43 1.We note your accounting policy disclosure that you reclassify disposal groups as held for sale when the held for sale criteria are met and that you report disposal groups as discontinued operations when the discontinued operations criteria are met. Please tell us what consideration you gave to including a discussion of these criteria and how the Grace Disposal Group met them within your critical accounting estimates. In addition, please tell us how you determined the Grace Disposal Group met the held for sale and discontinued operations criteria. 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 Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with
FirstName LastNameClayton Chun Comapany NameAlexander & Baldwin, Inc. June 22, 2023 Page 2 FirstName LastName Clayton Chun Alexander & Baldwin, Inc. June 22, 2023 Page 2 any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
June 22, 2023
Clayton Chun
Executive Vice President, Chief Financial Officer and Treasurer
Alexander & Baldwin, Inc.
822 Bishop Street
Post Office Box 3440
Honolulu, Hawaii 96801
Re:Alexander & Baldwin, Inc.
Form 10-K for the year ended December 31, 2022
File No. 001-35492
Dear Clayton Chun:
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 year ended December 31, 2022
Critical Accounting Estimates, page 43
1.We note your accounting policy disclosure that you reclassify disposal groups as held for
sale when the held for sale criteria are met and that you report disposal groups as
discontinued operations when the discontinued operations criteria are met. Please tell us
what consideration you gave to including a discussion of these criteria and how the Grace
Disposal Group met them within your critical accounting estimates. In addition, please
tell us how you determined the Grace Disposal Group met the held for sale and
discontinued operations criteria.
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 Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with
FirstName LastNameClayton Chun
Comapany NameAlexander & Baldwin, Inc.
June 22, 2023 Page 2
FirstName LastName
Clayton Chun
Alexander & Baldwin, Inc.
June 22, 2023
Page 2
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction