SEC Comment Letter for APi Group Corp (APG) (CIK 0001796209) (APG) — Nov 2, 2021
APi Group Corp (APG) (CIK 0001796209)
Date: Nov. 2, 2021 · CIK: 0001796209 · Accession: 0000000000-21-013287
AI Filing Summary & Sentiment
File numbers found in text: 001-39275
Letter
United States securities and exchange commission logo November 2, 2021 Kevin Krumm Chief Financial Officer APi Group Corp 1100 Old Highway 8 NW New Brighton, MN 55112 Re:APi Group Corp Form 10-K for the year ended December 31, 2020 Filed on March 24, 2021 Form 8-K filed on August 11, 2021 File No. 001-39275 Dear Mr. Krumm: We have reviewed your October 29, 2021 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 26, 2021 letter. Form 8-K filed on August 11, 2021 General 1.We note your response to our comment. While it is noted that the step-up adjustment will no longer be necessary after September 30, 2021, due to the comparative nature of your non-GAAP presentations which include prior periods, it appears that such adjustment will continue to be presented in filings subsequent to your September 30, 2021 filings. Please remove this adjustment from all future filings including any filings reflecting comparative periods that previously included such an adjustment. You may contact Ameen Hamady at 202-551-3891 or in his absence, Shannon Menjivar at 202-551-3856 if you have any questions.
FirstName LastNameKevin Krumm Comapany NameAPi Group Corp November 2, 2021 Page 2 FirstName LastName Kevin Krumm APi Group Corp November 2, 2021 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
November 2, 2021
Kevin Krumm
Chief Financial Officer
APi Group Corp
1100 Old Highway 8 NW
New Brighton, MN 55112
Re:APi Group Corp
Form 10-K for the year ended December 31, 2020
Filed on March 24, 2021
Form 8-K filed on August 11, 2021
File No. 001-39275
Dear Mr. Krumm:
We have reviewed your October 29, 2021 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
October 26, 2021 letter.
Form 8-K filed on August 11, 2021
General
1.We note your response to our comment. While it is noted that the step-up adjustment will
no longer be necessary after September 30, 2021, due to the comparative nature of your
non-GAAP presentations which include prior periods, it appears that such adjustment will
continue to be presented in filings subsequent to your September 30, 2021 filings. Please
remove this adjustment from all future filings including any filings reflecting comparative
periods that previously included such an adjustment.
You may contact Ameen Hamady at 202-551-3891 or in his absence, Shannon Menjivar
at 202-551-3856 if you have any questions.
FirstName LastNameKevin Krumm
Comapany NameAPi Group Corp
November 2, 2021 Page 2
FirstName LastName
Kevin Krumm
APi Group Corp
November 2, 2021
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction