SEC Comment Letter 0000000000-24-013154 to Custom Truck One Source, Inc. (CTOS)
Custom Truck One Source, Inc.
Date: Nov. 26, 2024 · CIK: 0001709682 · Accession: 0000000000-24-013154
AI Filing Summary & Sentiment
Letter
November 26, 2024 Christopher Eperjesy Chief Financial Officer Custom Truck One Source, Inc. 7701 Independence Ave Kansas City, MO 64125 Re:Custom Truck One Source, Inc. Form 8-K filed October 30, 2024 Response dated August 16, 2024 File No. 1-38186 Dear Christopher Eperjesy: We have reviewed your filing and have the following comment(s). 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. Form 8-K filed October 30, 2024 Exhibit 99.1, page 1 1.We note your response to prior comment 2. The adjustments for Non-cash purchase accounting impact and Sales-type lease adjustment in your reconciliation of Adjusted EBITDA as a non-GAAP performance measure result in a misleading measure that does not comply with Rule 100(b) of Regulation G. As such, Adjusted EBITDA, as currently calculated, should no longer be presented as a non-GAAP performance measure in future filings and other disclosures. 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 Tony Watson at 202-551-3318 or Adam Phippen at 202-551-3336 if you have questions regarding comments on the financial statements and related matters.
November 26, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
November 26, 2024
Christopher Eperjesy
Chief Financial Officer
Custom Truck One Source, Inc.
7701 Independence Ave
Kansas City, MO 64125
Re:Custom Truck One Source, Inc.
Form 8-K filed October 30, 2024
Response dated August 16, 2024
File No. 1-38186
Dear Christopher Eperjesy:
We have reviewed your filing and have the following comment(s).
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.
Form 8-K filed October 30, 2024
Exhibit 99.1, page 1
1.We note your response to prior comment 2. The adjustments for Non-cash purchase
accounting impact and Sales-type lease adjustment in your reconciliation of Adjusted
EBITDA as a non-GAAP performance measure result in a misleading measure that
does not comply with Rule 100(b) of Regulation G. As such, Adjusted EBITDA, as
currently calculated, should no longer be presented as a non-GAAP performance
measure in future filings and other disclosures.
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 Tony Watson at 202-551-3318 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters.
November 26, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Trade & Services