SEC Comment Letter 0000000000-25-003069 to REV Group, Inc. (REVG) (CIK 0001687221)
REV Group, Inc. (REVG) (CIK 0001687221)
Date: March 21, 2025 · CIK: 0001687221 · Accession: 0000000000-25-003069
AI Filing Summary & Sentiment
File numbers found in text: 001-37999
Referenced dates: March 17, 2025
Letter
March 21, 2025 Amy A. Campbell Chief Financial Officer REV Group, Inc. 245 South Executive Drive, Suite 100 Brookfield, WI 53005 Re:REV Group, Inc. Form 10-K for the Fiscal Year Ended October 31, 2024 Form 8-K furnished December 11, 2024 Response letter dated March 17, 2025 File No. 001-37999 Dear Amy A. Campbell: We have reviewed your March 17, 2025 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 March 3, 2025 letter. Form 10-K for the Fiscal Year ended October 31, 2025 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Adjusted EBITDA and Adjusted Net Income, page 43 1.We note your response to prior comment 2 and are considering your response. Please explain to us in more detail the nature and amount of all types of costs included in the "restructuring related charges" adjustment for fiscal years 2023 and 2022, including why you do not believe the adjustments represent normal operating costs as considered in Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures.
March 21, 2025 Page 2 Please contact Claire Erlanger at 202-551-3301 or Kevin Woody at 202-551-3629 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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March 21, 2025
Amy A. Campbell
Chief Financial Officer
REV Group, Inc.
245 South Executive Drive, Suite 100
Brookfield, WI 53005
Re:REV Group, Inc.
Form 10-K for the Fiscal Year Ended October 31, 2024
Form 8-K furnished December 11, 2024
Response letter dated March 17, 2025
File No. 001-37999
Dear Amy A. Campbell:
We have reviewed your March 17, 2025 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 March 3,
2025 letter.
Form 10-K for the Fiscal Year ended October 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Adjusted EBITDA and Adjusted Net Income, page 43
1.We note your response to prior comment 2 and are considering your response. Please
explain to us in more detail the nature and amount of all types of costs included in the
"restructuring related charges" adjustment for fiscal years 2023 and 2022, including
why you do not believe the adjustments represent normal operating costs as
considered in Question 100.01 of the Compliance and Disclosure Interpretations for
Non-GAAP Financial Measures.
March 21, 2025
Page 2
Please contact Claire Erlanger at 202-551-3301 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing