SEC Comment Letter 0000000000-24-009845 to Alexander & Baldwin, Inc. (ALEX) (CIK 0001545654) (ALEX)
Alexander & Baldwin, Inc. (ALEX) (CIK 0001545654)
Date: Aug. 29, 2024 · CIK: 0001545654 · Accession: 0000000000-24-009845
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35492
Letter
August 29, 2024 Mr. Clayton K.Y. Chun Executive Vice President, Chief Financial Officer and Treasurer Alexander & Baldwin, Inc. 822 Bishop Street P. O. Box 3440 Honolulu, Hawaii 96801 Re:Alexander & Baldwin, Inc. Form 10-K for the Year Ended December 31, 2023 Filed February 29, 2024 Form 8-K Filed July 25, 2024 File No. 001-35492 Dear Mr. Clayton K.Y. Chun: We have reviewed your filing and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K filed on July 25, 2024 Exhibit 99.1, page 3 1.We note you have provided several forward-looking non-GAAP measures, but have not provided quantitative reconciliations to the most directly comparable GAAP financial measures. Please revise your presentation in future filings to provide the required reconciliations, or, if relying on the exception provided by Item 10(e)(1)(i)(B) of Regulation S-K, provide the reason such reconciliation has not been provided, the information that is not available, and the significance of that information. Refer to Question 102.10(b) of the non-GAAP C&DIs. 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.
August 29, 2024 Page 2 Please contact Kellie Kim at 202-551-3129 or Shannon Menjivar at 202-551-3856 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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August 29, 2024
Mr. Clayton K.Y. Chun
Executive Vice President, Chief Financial Officer and Treasurer
Alexander & Baldwin, Inc.
822 Bishop Street
P. O. Box 3440
Honolulu, Hawaii 96801
Re:Alexander & Baldwin, Inc.
Form 10-K for the Year Ended December 31, 2023
Filed February 29, 2024
Form 8-K Filed July 25, 2024
File No. 001-35492
Dear Mr. Clayton K.Y. Chun:
We have reviewed your filing and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 8-K filed on July 25, 2024
Exhibit 99.1, page 3
1.We note you have provided several forward-looking non-GAAP measures, but have not
provided quantitative reconciliations to the most directly comparable GAAP financial
measures. Please revise your presentation in future filings to provide the required
reconciliations, or, if relying on the exception provided by Item 10(e)(1)(i)(B) of
Regulation S-K, provide the reason such reconciliation has not been provided, the
information that is not available, and the significance of that information. Refer to
Question 102.10(b) of the non-GAAP C&DIs.
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.
August 29, 2024
Page 2
Please contact Kellie Kim at 202-551-3129 or Shannon Menjivar at 202-551-3856 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction