SEC Comment Letter 0000000000-24-007883 to ALTA EQUIPMENT GROUP INC. (ALTG, ALTG-PA) (CIK 0001759824) (ALTG)
ALTA EQUIPMENT GROUP INC. (ALTG, ALTG-PA) (CIK 0001759824)
Date: July 11, 2024 · CIK: 0001759824 · Accession: 0000000000-24-007883
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38864
Letter
July 11, 2024 Anthony Colucci Chief Financial Officer Alta Equipment Group Inc. 13211 Merriman Road Livonia, MI 48150 Re:Alta Equipment Group Inc. Form 10-K Fiscal Year Ended December 31, 2023 File No. 001-38864 Dear Anthony Colucci: We have limited our review of your filing to the financial statements and related disclosures 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 10-K for Fiscal Year Ended December 31, 2023 Consolidated Statements of Cash Flows for the Years Ended December 31, 2023 and 2022, page 1.Please explain to us the basis for your balance sheet and cash flow statement classification of inventory and rental equipment, including purchases and sales of, and transfers between, inventory and rental equipment. Please be detailed in your response and address circumstances that may result in transactions being classified differently. As part of your response please describe the nature of your transactions, such as the typical time equipment is rented prior to sale (if known), the predominant source of use of the cash flows derived from equipment that is first rented and later sold, and any other factors affecting classification. 2.Please explain your consideration of presenting cash receipts from borrowings and cash outflows for payments on your manufacturing floor plans payable on a gross basis for the year ended December 31, 2023. Refer to ASC 230-10-45-7 through ASC 230-10-45-9.
July 11, 2024 Page 2 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 Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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July 11, 2024
Anthony Colucci
Chief Financial Officer
Alta Equipment Group Inc.
13211 Merriman Road
Livonia, MI 48150
Re:Alta Equipment Group Inc.
Form 10-K Fiscal Year Ended December 31, 2023
File No. 001-38864
Dear Anthony Colucci:
We have limited our review of your filing to the financial statements and related
disclosures 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 10-K for Fiscal Year Ended December 31, 2023
Consolidated Statements of Cash Flows for the Years Ended December 31, 2023 and 2022, page
44
1.Please explain to us the basis for your balance sheet and cash flow statement classification
of inventory and rental equipment, including purchases and sales of, and transfers
between, inventory and rental equipment. Please be detailed in your response and address
circumstances that may result in transactions being classified differently. As part of your
response please describe the nature of your transactions, such as the typical time
equipment is rented prior to sale (if known), the predominant source of use of the cash
flows derived from equipment that is first rented and later sold, and any other factors
affecting classification.
2.Please explain your consideration of presenting cash receipts from borrowings and cash
outflows for payments on your manufacturing floor plans payable on a gross basis for the
year ended December 31, 2023. Refer to ASC 230-10-45-7 through ASC 230-10-45-9.
July 11, 2024
Page 2
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 Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services