SEC Comment Letter 0000000000-24-009918 to JELD-WEN Holding, Inc. (JELD) (CIK 0001674335) (JELD)
JELD-WEN Holding, Inc. (JELD) (CIK 0001674335)
Date: Aug. 30, 2024 · CIK: 0001674335 · Accession: 0000000000-24-009918
AI Filing Summary & Sentiment
File numbers found in text: 001-38000
Letter
August 30, 2024 Samantha Stoddard Executive Vice President and Chief Financial Officer JELD-WEN Holding, Inc. 2645 Silver Crescent Drive Charlotte, NC 28273 Re:JELD-WEN Holding, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Form 8-K filed February 20, 2024 Form 8-K filed May 6, 2024 Response dated July 19, 2024 File No. 001-38000 Dear Samantha Stoddard: We have reviewed your July 19, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our July 10, 2024 letter. Form 10-K for the fiscal year ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Segment Results, page 45 1.We note your non-GAAP reconciliations of Adjusted EBITDA on pages 46 and 47 include a subtotal column that you identify as “Total Operating Segments." Since each subtotal in this column represents a non-GAAP financial measure that would not comply with Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures, please revise your reconciliations in future flings to delete this subtotal column. This comment is also applicable to your presentation of this subtotal column in the Segment footnote, in earnings releases filed under Form 8-K, and in quarterly filings.
August 30, 2024 Page 2 Please contact Jeffrey Gordon at 202-551-3866 or Anne McConnell at 202-551-3709 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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August 30, 2024
Samantha Stoddard
Executive Vice President and Chief Financial Officer
JELD-WEN Holding, Inc.
2645 Silver Crescent Drive
Charlotte, NC 28273
Re:JELD-WEN Holding, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Form 8-K filed February 20, 2024
Form 8-K filed May 6, 2024
Response dated July 19, 2024
File No. 001-38000
Dear Samantha Stoddard:
We have reviewed your July 19, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our July 10, 2024 letter.
Form 10-K for the fiscal year ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Segment Results, page 45
1.We note your non-GAAP reconciliations of Adjusted EBITDA on pages 46 and 47
include a subtotal column that you identify as “Total Operating Segments." Since each
subtotal in this column represents a non-GAAP financial measure that would not comply
with Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP
Financial Measures, please revise your reconciliations in future flings to delete this
subtotal column. This comment is also applicable to your presentation of this subtotal
column in the Segment footnote, in earnings releases filed under Form 8-K, and in
quarterly filings.
August 30, 2024
Page 2
Please contact Jeffrey Gordon at 202-551-3866 or Anne McConnell at 202-551-3709 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing