SEC Comment Letter 0000000000-23-003870 to Blue Bird Corp (BLBD) (CIK 0001589526) (BLBD)
Blue Bird Corp (BLBD) (CIK 0001589526)
Date: April 18, 2023 · CIK: 0001589526 · Accession: 0000000000-23-003870
AI Filing Summary & Sentiment
File numbers found in text: 001-36267
Letter
United States securities and exchange commission logo April 18, 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 reviewed your April 12, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. 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. Unless we note otherwise, our references to prior comments are to comments in our March 28, 2023 letter. 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 your response to prior comment 1. Please tell us how your discussions in the Management’s Discussion and Analysis of Financial Condition and Results of Operations provide disclosures of known trends or uncertainties that are reasonably likely to have a material impact on the Company’s cash flows, liquidity, capital resources, cash requirements, financial position, or results of operations arising from, related to, or caused by the rising interest rates given that you do not have plans to enter into mitigating interest rate risk arrangements at this time. Refer to Rule 303(b) of Regulation S-K.
FirstName LastNameRazvan Radulescu Comapany NameBlue Bird Corp April 18, 2023 Page 2 FirstName LastName Razvan Radulescu Blue Bird Corp April 18, 2023 Page 2 Key Non-GAAP Financial Measures We Use to Evaluate Our Performance, page 31 2.In response to prior comment 2, you stated that the product redesign initiatives costs were incurred to meet or exceed certain government-mandated regulations, and that they occur infrequently and not on a set cadence. Please tell us when these expenses were incurred most recently by the Company prior to fiscal 2022. 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
April 18, 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 reviewed your April 12, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
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. Unless we note otherwise, our references to prior comments are to comments in our
March 28, 2023 letter.
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 your response to prior comment 1. Please tell us how your discussions in the
Management’s Discussion and Analysis of Financial Condition and Results of Operations
provide disclosures of known trends or uncertainties that are reasonably likely to have a
material impact on the Company’s cash flows, liquidity, capital resources, cash
requirements, financial position, or results of operations arising from, related to, or caused
by the rising interest rates given that you do not have plans to enter into mitigating interest
rate risk arrangements at this time. Refer to Rule 303(b) of Regulation S-K.
FirstName LastNameRazvan Radulescu
Comapany NameBlue Bird Corp
April 18, 2023 Page 2
FirstName LastName
Razvan Radulescu
Blue Bird Corp
April 18, 2023
Page 2
Key Non-GAAP Financial Measures We Use to Evaluate Our Performance, page 31
2.In response to prior comment 2, you stated that the product redesign initiatives costs were
incurred to meet or exceed certain government-mandated regulations, and that they occur
infrequently and not on a set cadence. Please tell us when these expenses were incurred
most recently by the Company prior to fiscal 2022.
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