SEC Comment Letter 0000000000-23-003058 to Blue Bird Corp (BLBD) (CIK 0001589526) (BLBD)
Blue Bird Corp (BLBD) (CIK 0001589526)
Date: March 28, 2023 · CIK: 0001589526 · Accession: 0000000000-23-003058
AI Filing Summary & Sentiment
File numbers found in text: 001-36267
Letter
United States securities and exchange commission logo March 28, 2023 Razvan Radulescu Chief Financial Officer Blue Bird Corp 3920 Arkwright Road, 2nd Floor Macon, Georgia 31210 Re:Blue Bird Corp Form 10-K for the Fiscal Year Ended October 1, 2022 Filed December 12, 2022 File No. 001-36267 Dear Razvan Radulescu: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended October 1, 2022 Managements Discussion and Analysis of Financial Condition and Results of Operations, page 1.We note that you had entered into a four year interest rate collar to partially mitigate your exposure to interest rate fluctuations, which terminated on September 30, 2022. In future filings, please describe in your disclosure how the interest rate fluctuations related to the credit facility impact your results of operations and cash flows, and describe any new measures you have taken to mitigate the interest rate risks, if any. Key Non-GAAP Financial Measures We Use to Evaluate Our Performance, page 31 2.We note that your adjusted EBITDA reflect adjustments for “Operational transformation initiatives” and “Product redesign initiatives”. These adjustments were also included in the calculations of non-GAAP measures disclosed in the earnings release for fiscal 2022. Please tell us the nature of these adjustments and how you considered Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretation.
FirstName LastNameRazvan Radulescu Comapany NameBlue Bird Corp March 28, 2023 Page 2 FirstName LastName Razvan Radulescu Blue Bird Corp March 28, 2023 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Melissa Gilmore, Senior Staff Accountant, at 202-551-3777 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
March 28, 2023
Razvan Radulescu
Chief Financial Officer
Blue Bird Corp
3920 Arkwright Road, 2nd Floor
Macon, Georgia 31210
Re:Blue Bird Corp
Form 10-K for the Fiscal Year Ended October 1, 2022
Filed December 12, 2022
File No. 001-36267
Dear Razvan Radulescu:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended October 1, 2022
Managements Discussion and Analysis of Financial Condition and Results of Operations, page
26
1.We note that you had entered into a four year interest rate collar to partially mitigate your
exposure to interest rate fluctuations, which terminated on September 30, 2022. In future
filings, please describe in your disclosure how the interest rate fluctuations related to the
credit facility impact your results of operations and cash flows, and describe any new
measures you have taken to mitigate the interest rate risks, if any.
Key Non-GAAP Financial Measures We Use to Evaluate Our Performance, page 31
2.We note that your adjusted EBITDA reflect adjustments for “Operational transformation
initiatives” and “Product redesign initiatives”. These adjustments were also included in
the calculations of non-GAAP measures disclosed in the earnings release for fiscal 2022.
Please tell us the nature of these adjustments and how you considered Question 100.01 of
the Non-GAAP Financial Measures Compliance and Disclosure Interpretation.
FirstName LastNameRazvan Radulescu
Comapany NameBlue Bird Corp
March 28, 2023 Page 2
FirstName LastName
Razvan Radulescu
Blue Bird Corp
March 28, 2023
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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Melissa
Gilmore, Senior Staff Accountant, at 202-551-3777 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing