Electronics & Electrical Equipment

8 SEC staff comments and 22 disclosure examples from companies in this industry.

SIC codes included: 3690 Miscellaneous Electrical Machinery, Equipment & Supplies, 3663 Radio & Tv Broadcasting & Communications Equipment, 3669 Communications Equipment, NEC, 3600 Electronic & Other Electrical Equipment (No Computer Equip), 3679 Electronic Components, NEC, 3620 Electrical Industrial Apparatus, 3640 Electric Lighting & Wiring Equipment, 3621 Motors & Generators

Disclosure examples by topic

What the SEC staff asked companies in this industry

MD&A: Results & Known Trends (4)Segment Reporting (ASC 280) (4)Goodwill & Asset Impairment (3)Fair Value & Investments (2)Income Taxes (1)Debt, Equity & Derivatives (1)Business Description (Item 101) (1)Financial Statement Requirements (Reg S-X) (1)Filer Status & Cover Page (1)

SMITH A O CORP (AOS) · 2026-04-21 · A.O. Smith Corporation Form 10-K for the year ended December 31, 2025 · Comment 1 · Income Taxes, page 50 Partly revised / explained

Staff comment: Your MD&A attributes the 2025 effective tax rate change to reduced U.S. cross-border taxes, yet your rate reconciliation lacks a corresponding category. Additionally, you cite a “one-time tax adjustment” from a tax law change as a cash flow benefit, but this is not separately identified in your reconciliation as required by ASC 740-10-50-12A(a). Please tell us and disclose in future filings the details of the specific tax law change. Also, clarify how these items are currently reflected in your reconciliation and why they do not warrant separate presentation. letter →

Company response: We respectfully acknowledge the Staff's comment and are providing additional details and references to identify the materiality considerations that we used when determining the items to disclose in MD&A, as well as the referenced rate reconciliation contained within Note 14, Income Taxes. The “one-time tax adjustment” referenced as a cash flow benefit on page 23 in Liquidity and Capital Resources relates to changes to the timing of deduction of previously capitalized domestic research and development expenses under IRC Section 174 from the One Big Beautiful Bill Act. We are deducting the remaining unamortized domestic research and development costs over two years (half in 2025 and the other… response letter →

MD&A: Results & Known Trends Income Taxes Debt, Equity & Derivatives

ESCO TECHNOLOGIES INC (ESE) · 2026-03-11 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed December 1, 2025 · Comment 1 · Note 10. Business Segment Information, page F-28 Agreed to revise

Staff comment: We note your response to prior comment 2, including your proposed reconciliation of segment assets to consolidated assets. Please tell us how you determined the line currently titled “Corporate Assets” contains no significant items that should be separately identified and described. For example, it appears almost half of “Corporate Assets” may consist of goodwill not allocated to segments, and other acquired intangible assets not allocated to segments may represent a significant portion of the remainder. See ASC 280-10-50-31 and 280-10-55-49 for guidance. letter →

Company response: to prior comment 2, including your proposed reconciliation of segment assets to consolidated assets. Please tell us how you determined the line currently titled “Corporate assets” contains no significant items that should be separately identified and described. For example, it appears almost half of “Corporate assets” may consist of goodwill not allocated to segments, and other acquired intangible assets not allocated to segments may represent a significant portion of the remainder. See ASC 280-10-50-31 and 280-10-55-49 for guidance. Company Response In future filings, we will present the reconciliation from segment assets to consolidated asset totals in more detail by including the… response letter →

Segment Reporting (ASC 280)Goodwill & Asset Impairment

Atkore Inc. (ATKR) · 2026-03-10 · Form 10-K for the Year Ended September 30, 2025 Filed November 26, 2025 · Comment 1 · Business Factors Influencing our Results of Operations, page 37 Agreed to revise

Staff comment: We note the discussion of economic conditions influencing your operations beginning on page 37. You indicate that you generally sell your products on a spot basis and as such, were exposed to sales prices on your products that decreased faster than the cost of the related raw materials. We further note the analysis of segment results indicates the Electrical segment's average selling price decreased while its input costs increased and the Safety & Infrastructure segment's input costs decreased faster than its selling prices decreased, both of which seem somewhat different from the statement on page 37. Please explain to us in more detail the meaning of the disclosure on page 37 and how it… letter →

Company response: The disclosure referenced on page 37 that states, "We generally sell our products on a spot basis and as such, were exposed to sales prices on our products that decreased faster than the cost of the related raw materials" was intended 1 to convey an aggregated trend at the consolidated level and is reflected in the consolidated net sales and cost of sales explanations, on pages 40 and 41, where we disclose that "Net sales for fiscal 2025 decreased. . .primarily attributed to decreased average selling prices of $381.8 million" and "Cost of sales increased $50.1 million. . .the increase. . .was partially offset by lower input costs of $10.1 million." As the segment discussions are using… response letter →

Segment Reporting (ASC 280)MD&A: Results & Known Trends Business Description (Item 101)

Atkore Inc. (ATKR) · 2026-03-10 · Form 10-K for the Year Ended September 30, 2025 Filed November 26, 2025 · Comment 2 · Indefinite-Lived Intangible Assets and Goodwill Impairments, page 50 Agreed to revise

Staff comment: We note your disclosure that in fiscal 2025 you performed a quantitative impairment assessment for goodwill for your six reporting units. You recorded a goodwill impairment on the Mechanical reporting unit of $18.9 million as a result of this annual impairment test. You also indicated that the fair values of the Conduit & Fittings and EMEA reporting units exceed their respective carrying value, but changes in your valuation assumptions could have resulted in an impairment. However, you do not discuss the results of the remaining three reporting units. Please expand your critical accounting estimates disclosure to indicate whether the fair value substantially exceeds book value for all… letter →

Company response: Refer to Item 303(b)(3) of Regulation S-K and Section V of SEC Release No. 33-8350 for guidance. Company Response: In future filings, we will expand our critical accounting estimates disclosure to address all reporting units. We have included an example, italicized below, of what we would expect to disclose in a future filing assuming the facts and circumstances at September 30, 2025 and starting at the paragraph on page 51 beginning with "In fiscal 2025, the Company recorded a goodwill impairment on the Mechanical reporting unit of $18.9 million. . ." In fiscal 2025, the Company recorded a goodwill impairment on the Mechanical reporting unit of $18.9 million as a result of its annual… response letter →

MD&A: Results & Known Trends Goodwill & Asset Impairment Fair Value & Investments

LSI INDUSTRIES INC (LYTS) · 2026-02-27 · LSI Industries, Inc. Form 10-K for the Year Ended June 30, 2025 Filed September 11, 2025 · Comment 1 · General, page 30 Agreed to revise

Staff comment: We note that you have indicated on the cover page that you are an accelerated filer and your public float at December 31, 2024 was $580,496,057. Please tell us why you have only included two years of financial statements in your Form 10-K. Refer to Rules 3-01 and 3-02 of Regulation S-X. letter →

Company response: We acknowledge your comment and direction and recognize that smaller reporting company scaled disclosure alternatives were not applicable to our Form 10-K. The third year financial statement information is publicly available in our prior year Form 10-K and we confirm there have been no changes to that information. We will include three years of financial statements in our upcoming Form 10-K for the fiscal year ended June 30, 2026 in compliance with Rules 3-01 and 3-02 of Regulation S-X. response letter →

Financial Statement Requirements (Reg S-X)Filer Status & Cover Page

LSI INDUSTRIES INC (LYTS) · 2026-02-27 · LSI Industries, Inc. Form 10-K for the Year Ended June 30, 2025 Filed September 11, 2025 · Comment 2 · Note 4 – Business Segment Information, page 48 Agreed to revise

Staff comment: Please tell us how you comply with the requirements to disclose significant segment expenses and other segment items. If you have no significant expense categories, indicate where and how you explain the nature of the expense information the CODM uses to manage operations. If significant expense categories exist, explain how you plan to revise future disclosures to meet the requirements in ASC 280-10-50-26A through 26C. letter →

Company response: We acknowledge your comment regarding our compliance with the disclosure requirements of ASC 280-10-50-26A through 26C as it relates Note 4 – Segment Reporting. The CODM does not review disaggregated segment-level expenses beyond the amounts disclosed, but does review significant expenses at the consolidated level. The CODM delegates to segment leaders and function executives the responsibility of managing expenses. The Company will revise future disclosures to state the CODM does review expenses on a consolidated basis consistent with the categories of expenses on the consolidated statement of operations. The revised footnote disclosure will provide visibility of the consolidated expenses… response letter →

Segment Reporting (ASC 280)

ESCO TECHNOLOGIES INC (ESE) · 2026-02-24 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed December 1, 2025 · Comment 1 · Goodwill and Other Long-Lived Assets, page 27 Agreed to revise

Staff comment: We note the disclosure in your financial statement footnotes that you performed a quantitative impairment analysis related to certain reporting units and a qualitative impairment analysis related to other reporting units and concluded no goodwill was impaired. Given the significance of your goodwill balance, please revise your Critical Accounting Estimates in future filings to clarify whether any of your reporting units are at risk of failing the goodwill impairment test. A reporting unit is at risk of failing the impairment test if it has a fair value that is not substantially in excess of carrying value. If no reporting units are at risk based on your most recent impairment test, please… letter →

Company response: Refer to Item 303(b)(3) of Regulation S-K and Section V of SEC Release No. 33-8350 for guidance . Company Response In future filings, to the extent applicable, we will include as part of our critical accounting estimate disclosures the fact that no reporting units are at risk of failing the impairment test as they have a fair value that is substantially in excess of carrying value. Our proposed revised wording for this critical accounting estimate is below (changes underlined for emphasis). Proposed wording in future Form 10-K filings: Goodwill and Other Long-Lived Assets Our Management annually reviews goodwill and other long-lived assets for impairment or whenever events or changes in… response letter →

MD&A: Results & Known Trends Goodwill & Asset Impairment Fair Value & Investments

ESCO TECHNOLOGIES INC (ESE) · 2026-02-24 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed December 1, 2025 · Comment 2 · Note 10. Business Segment Information, page F-28 Agreed to revise

Staff comment: We note that your tabular disclosures of segment information beginning on page F-29 include separate columns for each of the reportable segments, a subtotal column for the reportable segments titled Segment Total, as well as a column for Corporate which is added to arrive at a Total column. It does not appear that your Corporate column qualifies as an operating and reportable segment under ASC 280. As such, the current disclosure appears to result in the presentation of certain amounts that are not required by ASC 280. Please revise your footnote as follows: • Reconcile the total of the reportable segments’ measures of segment profit or loss to consolidated income before taxes as required… letter →

Company response: , or explain to us why no revision is needed to comply with ASC 280. Company Response As noted in our footnote 10, Business Segment Information, we stated that Corporate is not a reportable segment, but it is included for reconciliation purposes. This is to help the reader reconcile our segment disclosures back to our consolidated statements of operations and balance sheets. In future filings, we will present the segment information in a different manner to reconcile to the consolidated totals, as outlined in Exhibit 1. response letter →

Segment Reporting (ASC 280)

Templates & resources

AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
Grant Thornton Insights (Grant Thornton · Firm guide · Free)
KPMG Financial Reporting View (KPMG · Firm guide · Free)
PwC Viewpoint (PwC · Firm guide · Free / paid)
RSM Financial Reporting Resource Center (RSM · Firm guide · Free)
SEC – Corporation Finance Interpretations (SEC · Regulator · Free)
SEC – Financial Reporting Manual (SEC · Regulator · Free)
The Monday Filer – SEC reporting Excel templates (The Monday Filer · Template vendor · Paid)
UnfoldCFO – 10-K Disclosure Checklist (UnfoldCFO · Template vendor · See site)
Workiva Marketplace – SEC Reporting Process Checklist (Workiva · Template vendor · Requires Workiva license)

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