SRSEC Reporting Desk

Titan Machinery Inc. (TITN) – SEC staff letter

2026-01-27 · Re: Form 10-K for Fiscal Year Ended January 31, 2025 · Accession 0000000000-26-000899 · 1 staff comment(s) issued

Company response(s): 2026-02-17

MD&A: Results & Known TrendsGoodwill & Asset ImpairmentFair Value & Investments

2026-01-27 · Form 10-K for Fiscal Year Ended January 31, 2025 · Comment 1 · Goodwill, page 39 Agreed to revise
Staff comment: Please provide information for investors to assess the probability of future goodwill impairment charges. For example, please disclose whether your reporting units are at risk of failing the quantitative impairment test or that the fair value is substantially in excess of carrying value and is not at risk of failing. If a reporting unit is at risk of failing, you should disclose: • the percentage by which fair value exceeded carrying value at the date of the most recent test; • a more detailed description of the methods and key assumptions used and how the key assumptions were determined; • a discussion of the degree of uncertainty associated with the assumptions; and • a description of… letter →
Company response: We acknowledge the Staff’s comment. In response thereto, we advise the Staff that in our presentation in future filings, commencing with the next 10-K filing, we will disclose if the fair value of a reporting unit substantially exceeds carrying value and is not at risk of failing, or if the fair value of a reporting unit does not substantially exceed the carrying value of the reporting unit, we will include the following disclosures: • the percentage by which fair value exceeded carrying value at the date of the most recent test; • a more detailed description of the methods and key assumptions used and how the key assumptions were determined; • a discussion of the degree of uncertainty… response letter →
MD&A: Results & Known TrendsGoodwill & Asset ImpairmentFair Value & Investments

Full letter on EDGAR → · Filing index · All Titan Machinery Inc. (TITN) correspondence

MD&A: Results & Known Trends – what to check: Quantify drivers of changes (price vs. volume), discuss known trends and uncertainties, and avoid repeating the financial statements.

Goodwill & Asset Impairment – what to check: Disclose reporting units at risk, headroom, key assumptions and triggering-event analysis, especially if market cap is below book value.

Fair Value & Investments – what to check: Disclose Level 3 valuation techniques and significant unobservable inputs, and support equity-method vs. fair value elections.

Templates & resources

Listed alphabetically by provider. Listings are not endorsements; no provider pays for placement. All templates & resources