SEC Comment Letter 0000000000-23-002032 to ASHLAND INC. (ASH) (CIK 0001674862) (ASH)
ASHLAND INC. (ASH) (CIK 0001674862)
Date: March 1, 2023 · CIK: 0001674862 · Accession: 0000000000-23-002032
AI Filing Summary & Sentiment
File numbers found in text: 333-211719
Letter
United States securities and exchange commission logo March 1, 2023 J. Kevin Willis Chief Financial Officer Ashland Inc. 8145 Blazer Drive Wilmington, Delaware 19808 Re:Ashland Inc. Form 10-K for Fiscal Year Ended September 30, 2022 Filed November 21, 2022 File No. 333-211719 Dear J. Kevin Willis: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for Fiscal Year Ended September 30, 2022 Liquidity Free cash flow and other liquidity resources, page M-27 1.Please present the most directly comparable GAAP measure to the non-GAAP measure "ongoing free cash flow conversion". Refer to footnote 27 of the SEC Final Rule Release Number 33-8176. Additionally, disclose why management believes the presentation of this measure provides useful information to investors, and to the extent material, disclose the additional purposes, if any, for which management uses the measure. Refer to Item 10(e)(1)(i) of Regulation S-K.
FirstName LastNameJ. Kevin Willis Comapany NameAshland Inc. March 1, 2023 Page 2 FirstName LastName J. Kevin Willis Ashland Inc. March 1, 2023 Page 2 Critical Accounting Policies Asbestos litigation, page M-36 2.We note that asbestos-related liabilities are now based on a 40-year model instead of a 50- year model. Please disclose this change, the reason for the change, and if material, any change in estimates that resulted from the change. Refer to Item 303(b)(3) of Regulation S-K. 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 Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551- 3307 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 1, 2023
J. Kevin Willis
Chief Financial Officer
Ashland Inc.
8145 Blazer Drive
Wilmington, Delaware 19808
Re:Ashland Inc.
Form 10-K for Fiscal Year Ended September 30, 2022
Filed November 21, 2022
File No. 333-211719
Dear J. Kevin Willis:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for Fiscal Year Ended September 30, 2022
Liquidity
Free cash flow and other liquidity resources, page M-27
1.Please present the most directly comparable GAAP measure to the non-GAAP measure
"ongoing free cash flow conversion". Refer to footnote 27 of the SEC Final Rule Release
Number 33-8176. Additionally, disclose why management believes the presentation of
this measure provides useful information to investors, and to the extent material, disclose
the additional purposes, if any, for which management uses the measure. Refer to Item
10(e)(1)(i) of Regulation S-K.
FirstName LastNameJ. Kevin Willis
Comapany NameAshland Inc.
March 1, 2023 Page 2
FirstName LastName
J. Kevin Willis
Ashland Inc.
March 1, 2023
Page 2
Critical Accounting Policies
Asbestos litigation, page M-36
2.We note that asbestos-related liabilities are now based on a 40-year model instead of a 50-
year model. Please disclose this change, the reason for the change, and if material, any
change in estimates that resulted from the change. Refer to Item 303(b)(3) of Regulation
S-K.
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 Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-
3307 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services