SRSEC Reporting Desk

Concentrations & Receivables

What to check in your filing: Review recent comments below against your own disclosure.

8 staff comments from 7 companies. Outcomes: Explained / pushed back: 3, Responded: 2, Awaiting / response not in dataset: 2, Agreed to revise: 1

Fortune Brands Innovations, Inc. (FBIN) · 2026-03-27 · Form 10-K for the year ended December 27, 2025 Form 8-K furnished February 12, 2026 · Comment 4 · Exhibit 99.1 Earnings Release, page 6 Responded
Staff comment: We note that your non-GAAP performance measures such as Diluted EPS from continuing operations before charges/gains, and operating income and margin before charges/gains shown on a consolidated basis, and by segment, include an adjustment for “other charges/gains.” We further note from your disclosure on page 13 that “other charges/(gains)” represent costs that are directly related to restructuring initiatives but cannot be reported as restructuring costs under GAAP. These costs can include losses from disposing of inventories, trade receivables allowances from discontinued product lines, accelerated depreciation due to the closure of facilities, gains or losses from selling previously… letter →
Company response: The Company acknowledges the Staff’s comment and confirms that the Company has considered the guidance in Question 100.01 of the Corporation Finance Interpretations on Non-GAAP Financial Measures. The Company confirms that the adjustment for these costs are not part of normal operations, as discussed below, and that the Company believes that the Company’s presentation of diluted earnings per share from continuing operations before charges/gains and operating income and margin before charges/gains shown is appropriate under the circumstances to give investors a representation of normal operating performance and period-to-period comparability. The items included as adjustments within “other… response letter →
Non-GAAP: Reconciliation & UsefulnessSegment Reporting (ASC 280)Earnings per Share (ASC 260)Exhibits, Certifications & SignaturesConcentrations & Receivables
OneConstruction Group Ltd (ONEG) · 2026-03-24 · Form 20-F for the Fiscal Year Ended March 31, 2025 Response dated March 10, 2026 · Comment 2 · 1. We note your response to comment Explained / pushed back
Staff comment: Please tell us what consideration you have given to disclosing information about your past due accounts receivables. Reference is made to the guidance outlined in paragraphs 326-20-55-37 through 40 of the Financial Accounting Standards Codification. letter →
Company response: The Company respectfully advises the Staff that it considered the guidance in ASC 326-20, including the illustrative Example 5 in paragraphs 55-37 through 55-40, in developing its accounting policy for measuring expected credit losses on accounts receivable and determining the related disclosures. In evaluating the need for additional disclosures regarding past-due accounts receivable, the Company specifically considered whether quantitative aging disclosures or further qualitative discussion would be necessary to enable users to understand the credit risk profile of the portfolio, consistent with ASC 326-20-50-2 and 50-3. This assessment included consideration of the proportion of past-due… response letter →
Concentrations & Receivables
AEHR TEST SYSTEMS (AEHR) · 2026-03-17 · Inc. Form 10-K for the Fiscal Year Ended May 30, 2025 Form 10-Q for the Three and Six Months Ended November 28, 2025 · Comment 4 · Note 13. Segment and Concentration Information, page 19 Explained / pushed back
Staff comment: We see your discussion in MD&A that the rapid advancement of generative artificial intelligence (AI) and the accelerating electrification of transportation and global infrastructure represent two of the most significant macro-trends impacting the semiconductor industry today. These appear to represent two different end markets for your products as well, one with decreasing sales, and one with increasing sales, based on your reporting. Tell us how the changes in your business and related end markets impact how management reviews the business, your determination of operating segments, and all other general segment disclosures, including revenue by end market. letter →
Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that management has considered the impact of changes in its business and related end markets, including demand associated with generative AI and the electrification of transportation and infrastructure, in its determination of operating segments and related disclosures. As disclosed in Note 16 to the Company’s fiscal 2025 Annual Report on Form 10-K and Note 13 to the Company’s Quarterly Report on Form 10-Q for the quarter ended November 28, 2025, the Company has concluded that it operates as a single operating and reportable segment. The Company’s Chief Operating Decision Maker (“CODM”) reviews financial… response letter →
Segment Reporting (ASC 280)MD&A: Results & Known TrendsBusiness Description (Item 101)Concentrations & Receivables
Electromed, Inc. (ELMD) · 2026-03-16 · Form 10-K For the Fiscal Year Ended June 30, 2025 Filed August 26, 2025 · Comment 2 · Accounts Receivable, page F-8 Awaiting / response not in dataset
Staff comment: Please provide us and in future filings a rollforward of the allowance for credit losses, as set forth in ASC 326-20-50-13. In addition, please provide us and in future filings the amount of accounts receivable that have been outstanding for greater than one year for the Balance Sheet dates presented and December 31, 2025. letter →
Insurance & Credit Loss ReservesConcentrations & Receivables
OneConstruction Group Ltd (ONEG) · 2026-02-12 · Form 20-F for the Fiscal Year Ended March 31, 2025 · Comment 2 · 3. Concentration of Risks, page F-12 Explained / pushed back
Staff comment: We note that over 38% of your accounts receivable balance as of March 31, 2025, $8.9M, is due from a single customer, and that your revenues from that customer during the 12 months ended March 31, 2025 were only $1.8M. Please clarify whether any amounts due from this customer were past due as of March 31, 2025, and if these amounts have been subsequently collected. To the extent any of these amounts remain outstanding as of September 30, 2025, please tell us if you have recorded any credit loss allowance. letter →
Company response: The Company respectfully advises the Staff that the accounts receivable balance from the customer in question included amounts that were past due as of March 31, 2025. The Company has subsequently collected a significant portion of this balance. Specifically, the aging of the gross accounts receivable of $8,888,000 from this customer as of March 31, 2025, was as follows: Not yet past due: $ 1,340,000 Past due over 180 days but within 1 year: $ 3,841,000 Past due over 1 year but within 2 years: $ 3,707,000 Total Gross Accounts Receivable: $ 8,888,000 As of March 31, 2025, the Company had recorded an allowance for credit loss of $148,000 against this receivable, resulting in a net accounts… response letter →
Concentrations & Receivables
Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-01-30 · · Comment 7 · Item 4.B. Business Overview, page 24 Awaiting / response not in dataset
Staff comment: We refer to page F-16, which indicates that nearly all of your revenues derive from product sales in Ireland and the United States, and your disclosure on page 28 that Scenesse for EPP patients accounted for approximately 90% of your sales in FY2025. Accordingly, please revise the Overview section to discuss the concentration of sales in these two jurisdictions. Also, revise your Marketing and Sales section to discuss your operations, as well as the coverage, pricing and reimbursement for Scenesse, in these two jurisdictions. letter →
IFRS & Foreign Private IssuersConcentrations & Receivables
Accordant ODCE Index Fund · 2026-01-16 · (the “Registrant”) · Comment 5 · Comment Responded
Staff comment: The SEC staff notes that the Registrant includes a line item titled “Receivable due from Adviser” in the Statement of Assets and Liabilities. Please describe in correspondence the frequency that this receivable from the Adviser is settled and whether settlement terms are the same terms as the payments to the Adviser. letter →
Company response: 5 . The Registrant synchronizes the frequency that the receivable from the Adviser is settled with the settlement terms of payments to the Adviser, such that such payments will be made on a monthly basis. The Registrant notes that as of December 31, 2025, the receivable due from the Adviser has decreased to approximately $168,000 from approximately $606,000 as of June 30, 2025. response letter →
Funds & BDCs (ASC 946, N-CSR)Concentrations & Receivables
UPBOUND GROUP, INC. (UPBD) · 2025-10-17 · Form 10-K for the Fiscal Year Ended December 31, 2024 Form 10-Q for Fiscal Period Ended June 30, 2025 · Comment 2 Agreed to revise
Staff comment: You attribute the decrease in reported cash provided by operating activities in fiscal 2024 compared to fiscal 2023 of $95.6 million solely to an increase in your inventory purchases, which appears to be about $57 million based on the change between 2024 and 2023 in the line Rental Merchandise reported in the statement of cash flows. Based on changes in amounts reported in the statement of cash flows, it appears other factors materially affected the change in operating cash flows between these periods that have not been discussed. For example, net earnings/loss, adjusted for adjustments to reconcile net earnings (loss) to net cash provided by operating activities, increased $120 million,… letter →
Company response: The Company acknowledges the Staff’s comment, and in future filings, beginning with our Form 10-Q for the quarter ended September 30, 2025, we will expand disclosures to provide additional quantitative information related to material factors contributing to period-over-period changes in our operating cash flows. In future filings, we intend to expand our disclosures to be similar to the example provided in the below revised disclosure excerpts from our Form 10-K for the year ended December 31, 2024, within the Analysis of Cash Flow section of Management’s Discussion and Analysis of Financial Condition and Results of Operations. Our revisions are marked in bold. Form 10-K for year-ended… response letter →
MD&A: Results & Known TrendsStatement of Cash Flows (ASC 230)Concentrations & Receivables
Free weekly digest

New SEC comment letters by topic, notable staff comments, fresh disclosure examples and effective-date reminders. One email a week.

Templates & resources

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