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TPRTapestry, Inc.

Consumer discretionary · Leather Goods · NYSE
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SEC comment letters, last 20 years

1 review of TPR's filings by SEC staff

UPLOAD and CORRESP
ReviewsRead ↓
1
latest letter 2020-01-31
Questions asked
1
each answered in the company's own letter
No closing letter
0
reviews without a letter saying the staff completed it

When the SEC's staff reviews a filing, it writes to the company with numbered questions, and the company answers each one in a letter. SEC publishes the exchange once the review is over, at least 20 business days later. A question is not an accusation; most reviews end with the company adding detail to its next filing.

Form 10-K for the Fiscal Year Ended June 29, 2019

2020-01-31 to 2020-02-14 · 1 question · 1 letter from the SEC, 1 from the company
Review closed 2020-02-14
Non-GAAP measuresSegmentsResults discussion (MD&A)Acquisitions
Item 7. Management's Discussion and Analysis of Financial Condition and Results of · Operations, page 29
SEC asked
Your narrative of the year-to-year fluctuations, in the summary and segment performance sections, consistently use the phrase “excluding non-GAAP charges” to refer to the expenses incurred for ERP implementation, integration and acquisition, and the impact of the tax legislation that you excluded as adjustments in your GAAP to Non-GAAP reconciliation.
Rest of the question

It appears to us that your use of this phrase may be confusing to an investor since the items you are excluding are not non-GAAP charges, but rather certain significant items affecting the comparability of your results of operations. Please revise future filings to eliminate the use of the term “non-GAAP charges” where you discuss the results of operations between periods, and characterize the nature of such charges differently. 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.

TPR answered
We acknowledge the Staff’s comment and confirm that in future filings we will eliminate the use of the term “non-GAAP charges” when discussing results of operations between periods. We will instead reference these charges as “items affecting comparability” or other similar terminology.

As stated in the comment letter, we hereby acknowledge that the Company is responsible for the accuracy and adequacy of the disclosure in our filings. Read in the reply ↗
In its next report

First report after the company's reply of 2020-02-12: 10-Q filed 2020-05-06 ↗, against the 10-Q filed 2019-11-07 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Also in this review: closing letter, 2020-02-14

Other letters

Letters without questions

UPLOAD and CORRESP
2 other letters: notices that a filing will not be reviewed, requests to declare a registration effective, and the like
  • 2017-06-20 · TPR: letter to the SEC · Kate Spade & Company · Schedule TO-T filed May 26, 2017, by Chelsea Merger Sub Inc....
  • 2017-06-08 · TPR: letter to the SEC · Kate Spade & Company · Schedule TO-T filed May 26, 2017, by Chelsea Merger Sub Inc....

From the SEC's correspondence on EDGAR: staff letters (form UPLOAD) and company letters (form CORRESP), 5 letters filed since 2017-06-08. Questions and answers are matched by their numbers; topics come from words in each question. The reports are compared word for word (same form, before the first SEC letter against the first report after the company's reply). No AI.

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