SEC Comment Letter 0000000000-23-012618 to Ecovyst Inc. (ECVT) (CIK 0001708035) (ECVT)
Ecovyst Inc. (ECVT) (CIK 0001708035)
Date: Nov. 17, 2023 · CIK: 0001708035 · Accession: 0000000000-23-012618
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38221
Letter
United States securities and exchange commission logo November 17, 2023 Michael Feehan Chief Financial Officer Ecovyst Inc. 300 Lindenwood Drive Malvern, PA 19355 Re:Ecovyst Inc. Form 10-K filed February 28, 2023 File No. 001-38221 Dear Michael Feehan: We have limited our review of your filing to the financial statements and related disclosures 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 this 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. Form 10-K for the Year Ended December 31, 2022 The Company, page 3 1.We note that your presentation of total sales by end use, destination geography and customer includes Zeolyst Joint Venture sales. In light of the fact that you account for this investment under the equity method of accounting, please tell us how you considered Rule 100(b) of Regulation G in determining whether this presentation results in an individually tailored accounting policy. Refer to Question 100.04 of the Non-GAAP C&DI's. 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. Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 with any questions.
FirstName LastNameMichael Feehan Comapany NameEcovyst Inc. November 17, 2023 Page 2 FirstName LastName Michael Feehan Ecovyst Inc. November 17, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
November 17, 2023
Michael Feehan
Chief Financial Officer
Ecovyst Inc.
300 Lindenwood Drive
Malvern, PA 19355
Re:Ecovyst Inc.
Form 10-K filed February 28, 2023
File No. 001-38221
Dear Michael Feehan:
We have limited our review of your filing to the financial statements and related
disclosures 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 this
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.
Form 10-K for the Year Ended December 31, 2022
The Company, page 3
1.We note that your presentation of total sales by end use, destination geography and
customer includes Zeolyst Joint Venture sales. In light of the fact that you account for this
investment under the equity method of accounting, please tell us how you considered Rule
100(b) of Regulation G in determining whether this presentation results in an individually
tailored accounting policy. Refer to Question 100.04 of the Non-GAAP C&DI's.
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.
Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 with
any questions.
FirstName LastNameMichael Feehan
Comapany NameEcovyst Inc.
November 17, 2023 Page 2
FirstName LastName
Michael Feehan
Ecovyst Inc.
November 17, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services