GPCGenuine Parts Company

Please remove the total segment profit and total segment profit margin non-GAAP measures from your filings or remove the corporate expense adjustment, since this adjustment appears to result in the exclusion of normal, recurring, cash operating expenses from these non-GAAP measures. Refer to Questions 100.01 and 104.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.

In future filings, we will no longer present total segment profit or total segment profit margin. Read in the reply ↗

Please revise the other assets and liabilities line item to present changes in other assets separately from other liabilities and further breakout any material components. Also, present acquisitions separately from other investing activities and further breakout any material components. Refer to ASC 230-10-45-7 and 45-29.

In future filings, we will present changes in other assets separately from changes in other liabilities and further breakout any material components. We will also present acquisitions of businesses separately from other investing activities and further breakout any material components. We will include this disclosure in our upcoming year end Form 10-K. Read in the reply ↗

Please disclose in greater detail the types of amounts included in the corporate expense line item of your segment reconciliation. Refer to ASC 280-10-50-31. Also, revise your management's discussion and analysis section to discuss with quantification the business reasons for material changes between periods in (a) each segment's profit and (b) any material reconciling items of the segment reconciliation in Note 2,

Rest of the question

such as corporate expense. In circumstances where there are more than one business reason for the change, such as in your Industrial segment discussion on page 24, please quantify the incremental impact of each individual business reason discussed on the overall change in the line item. Refer to Item 303 of Regulation S-K and SEC Release No. 33-8350.

In future filings, we will enhance our disclosure to provide further description of the nature of the corporate expense line item within our segment reconciliation in accordance with ASC 280-10-50-31.

An example of the disclosure we will include in future filings is provided as follows:

Corporate expense includes the costs of our corporate headquarters functions and certain other activities that provide broad-based support to our business units.

Rest of the answer

These costs primarily consist of salaries and benefits associated with executive leadership, human resources, technology, cybersecurity, legal, corporate finance, and internal audit personnel. Corporate expense also includes costs and fees arising from product liability claims, cash management activities and certain other programs that are managed centrally.

In addition, in future filings, our Management's Discussion and Analysis (MD&A) section will include a quantitative discussion of the business reasons for material changes between periods in each segment’s profit, along with any significant reconciling items, including corporate expense. When multiple business reasons contribute to a material change, we will quantify the incremental impact of the individual factors on the overall change in the line item, in accordance with Item 303 of Regulation S-K and SEC Release No. 33-8350.

We will include these additional disclosures in our upcoming year end Form 10-K.

Read in the reply ↗