SEC Comment Letter for Reynolds Consumer Products Inc. (REYN) (CIK 0001786431) (REYN) — Jan 23, 2020
Reynolds Consumer Products Inc. (REYN) (CIK 0001786431)
Date: Jan. 23, 2020 · CIK: 0001786431 · Accession: 0000000000-20-000625
AI Filing Summary & Sentiment
File numbers found in text: 333-234731
Letter
January 23, 2020 Lance Mitchell Chief Executive Officer Reynolds Consumer Products Inc. 1900 W. Field Court Lake Forest, IL 60045 Re:Reynolds Consumer Products Inc. Amendment No. 1 to Form S-1 Filed January 21, 2020 File Number 333-234731 Dear Mr. Mitchell: We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Amendment No. 2 to Form S-1 filed January 21, 2020 Executive Compensation, page 125 1.Please update your executive compensation disclosure to include your recently completed fiscal year. Please refer to Item 402 of Regulation S-K and Regulation S-K Compliance and Disclosure Interpretation 117.05.
FirstName LastNameLance Mitchell Comapany NameReynolds Consumer Products Inc. January 23, 2020 Page 2 FirstName LastName Lance Mitchell Reynolds Consumer Products Inc. January 23, 2020 Page 2 You may contact Ameen Hamady, Staff Accountant at (202) 551-3891 or Al Pavot, Staff Attorney at (202) 551-3738 if you have questions regarding comments on the financial statements and related matters. Please contact Sherry Haywood, Special Counsel at (202) 551- 3345 or Asia Timmons-Pierce, Staff Attorney at (202) 551-3754 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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January 23, 2020
Lance Mitchell
Chief Executive Officer
Reynolds Consumer Products Inc.
1900 W. Field Court
Lake Forest, IL 60045
Re:Reynolds Consumer Products Inc.
Amendment No. 1 to Form S-1
Filed January 21, 2020
File Number 333-234731
Dear Mr. Mitchell:
We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 2 to Form S-1 filed January 21, 2020
Executive Compensation, page 125
1.Please update your executive compensation disclosure to include your recently completed
fiscal year. Please refer to Item 402 of Regulation S-K and Regulation S-K Compliance
and Disclosure Interpretation 117.05.
FirstName LastNameLance Mitchell
Comapany NameReynolds Consumer Products Inc.
January 23, 2020 Page 2
FirstName LastName
Lance Mitchell
Reynolds Consumer Products Inc.
January 23, 2020
Page 2
You may contact Ameen Hamady, Staff Accountant at (202) 551-3891 or Al Pavot, Staff
Attorney at (202) 551-3738 if you have questions regarding comments on the financial
statements and related matters. Please contact Sherry Haywood, Special Counsel at (202) 551-
3345 or Asia Timmons-Pierce, Staff Attorney at (202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing