United States securities and exchange commission logo
October 24, 2022
Todd B. Patriacca
Chief Financial Officer
Altra Industrial Motion Corp.
300 Granite Street, Suite 201
Braintree, MA 02184
Re: Altra Industrial
Motion Corp.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 28,
2022
Form 8-K Furnished
July 28, 2022
File No. 001-33209
Dear Todd B. Patriacca:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 34
1. We note you present the
percentage of sales by end market in the Charts included as part
of your earnings
releases furnished each quarter on Forms 8-K and these results, as well as
a comparison to prior
periods, are discussed in detail in your earnings calls. Please tell us
your consideration of
including this information in the results of operations discussion in
your MD&A. In this
regard, we note you qualitatively refer to the impact various end
market results had on
changes in net sales; however, including quantitative information
for all end markets
would appear to add context to your discussion, as well as provide
information consistent
with what is disclosed elsewhere.
Todd B. Patriacca
Altra Industrial Motion Corp.
October 24, 2022
Page 2
Form 8-K Furnished July 28, 2022
Exhibit 99.1, page 1
2. We note your non-GAAP measures exclude the results of the divested JVS
business. As
these divested operations did not meet the criteria for being presented
as discontinued
operations pursuant to ASC 205-20, your non-GAAP measures appear to
substitute
individually tailored recognition and measurement methods for those of
GAAP. Please
revise to remove these adjustments from each measure. Refer to Question
100.04 of the
Non-GAAP C&DIs.
3. Revise to include net income margin, the comparable GAAP measure to
adjusted
EBTIDA margin, with greater prominence. Also, revise to include, with
greater
prominence, income from operations as a percentage of net sales for each
segment, the
comparable GAAP measure to non-GAAP income from operations as a
percentage of
segment net sales. Refer to Item 10(e)(1)(i)(A) of Regulation S-K.
4. We note that your "Reconciliation of Non-GAAP Income from Operations by
Segment"
begins with income from operations by segment; however this does not
agree to your
GAAP segment measure of performance as disclosed on page 21 of your Form
10-Q for
the quarterly period ended June 30, 2022. Please revise accordingly.
In closing, 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.
You may contact Melissa Kindelan, Senior Staff Accountant, at (202)
551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions.
Sincerely,
FirstName LastNameTodd B. Patriacca
Division of
Corporation Finance
Comapany NameAltra Industrial Motion Corp.
Office of Technology
October 24, 2022 Page 2
cc: Glenn Deegan
FirstName LastName