SEC Comment Letter for Arconic Corp (CIK 0001790982) — Jan 7, 2020
Arconic Corp (CIK 0001790982)
Date: Jan. 7, 2020 · CIK: 0001790982 · Accession: 0000000000-20-000150
AI Filing Summary & Sentiment
File numbers found in text: 001-39162
Letter
January 7, 2020 Katherine Ramundo Executive Vice President, Chief Legal Officer and Corporate Secretary Arconic Rolled Products Corporation 201 Isabella Street Pittsburgh, Pennsylvania 15212 Re:Arconic Rolled Products Corporation Registration Statement on Form 10-12B Filed December 17, 2019 File No. 001-39162 Dear Ms. Ramundo: We have reviewed your filing 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 these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to these comments, we may have additional comments. Form 10 Management's Discussion and Analysis of Financial Condition and Results of Operations Segment Information, page 88 1.We note your response to prior comment 2; however, it continues to appear to us that you should revise your disclosures to quantify the impact of the factors that you identify as impacting segment sales and segment operating profit during each period presented, including the impact of changes in aluminium prices and volume sold and discuss the underlying factors that led to those changes. In this regard, it appears to us that Arconic provides quantified disclosures related to the impact of changes in aluminium prices and volume sold in earnings releases and analyst calls.
FirstName LastNameKatherine Ramundo Comapany NameArconic Rolled Products Corporation January 7, 2020 Page 2 FirstName LastName Katherine Ramundo Arconic Rolled Products Corporation January 7, 2020 Page 2 Financial Statements Statement of Changes in Combined Equity, page F-7 2.We note your response to prior comment 5; however, based on the significance of transactions with the ParentCo, it continues to appear to us that you should provide an analysis of the components included in the change in ParentCo contribution during each period presented and, to the extent applicable, reconcile those components to existing disclosures related to cost allocations and financing amounts reflected in the statements of cash flows. 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. You may contact Kevin Stertzel, Staff Accountant, at (202) 551-3723 or Anne McConnell, Staff Accountant, at (202) 551-3709 if you have questions regarding comments on the financial statements and related matters. Please contact Sherry Haywood, Staff Attorney, at (202) 551-3345 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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January 7, 2020
Katherine Ramundo
Executive Vice President, Chief Legal Officer and Corporate Secretary
Arconic Rolled Products Corporation
201 Isabella Street
Pittsburgh, Pennsylvania 15212
Re:Arconic Rolled Products Corporation
Registration Statement on Form 10-12B
Filed December 17, 2019
File No. 001-39162
Dear Ms. Ramundo:
We have reviewed your filing 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Form 10
Management's Discussion and Analysis of Financial Condition and Results of Operations
Segment Information, page 88
1.We note your response to prior comment 2; however, it continues to appear to us that you
should revise your disclosures to quantify the impact of the factors that you identify as
impacting segment sales and segment operating profit during each period presented,
including the impact of changes in aluminium prices and volume sold and discuss the
underlying factors that led to those changes. In this regard, it appears to us that Arconic
provides quantified disclosures related to the impact of changes in aluminium prices and
volume sold in earnings releases and analyst calls.
FirstName LastNameKatherine Ramundo
Comapany NameArconic Rolled Products Corporation
January 7, 2020 Page 2
FirstName LastName
Katherine Ramundo
Arconic Rolled Products Corporation
January 7, 2020
Page 2
Financial Statements
Statement of Changes in Combined Equity, page F-7
2.We note your response to prior comment 5; however, based on the significance of
transactions with the ParentCo, it continues to appear to us that you should provide an
analysis of the components included in the change in ParentCo contribution during each
period presented and, to the extent applicable, reconcile those components to existing
disclosures related to cost allocations and financing amounts reflected in the statements of
cash flows.
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.
You may contact Kevin Stertzel, Staff Accountant, at (202) 551-3723 or Anne
McConnell, Staff Accountant, at (202) 551-3709 if you have questions regarding comments on
the financial statements and related matters. Please contact Sherry Haywood, Staff Attorney,
at (202) 551-3345 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing