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United States securities and exchange commission logo
May 28, 2021
J. Michael Daniel
Senior Vice President and Chief Financial Officer
Bassett Furniture Industries Inc.
3525 Fairystone Park Highway
Bassett, Virginia 24055
Re: Bassett Furniture
Industries Inc.
Form 10-K for the
Fiscal Year Ended November 28, 2020
Response dated May
14, 2021
File No. 000-00209
Dear Mr. Daniel:
We have reviewed your May 14, 2021 response to our comment letter
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. Unless we note otherwise, our references to prior comments are
to comments in our
April 21, 2021 letter.
Response Letter dated May 14, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Analysis of Operations, page 17
1. We note your response
to comment 1 and reissue our prior comment. As noted in Item
303(b) of Regulation
S-K and SEC Release No. 33-8350, your results of operations
discussion should focus
on an analysis of your consolidated financial condition and
operating performance,
with segment data provided where material to an understanding of
consolidated
information. Accordingly, please address the following comments related to
your analysis of
operations discussion:
Revise your
disclosures in future filings to discuss year-over-year changes in net
sales to external
customers, cost of furniture and accessories sold, gross profit and
J. Michael Daniel
Bassett Furniture Industries Inc.
May 28, 2021
Page 2
gross profit margin, and selling, general and administrative
expenses on a
consolidated basis exclusive of inter-company amounts.
Revise your segment results disclosures to provide and discuss
changes in net sales to
external customers.
Notes to the Consolidated Financial Statements
Segment Information, page 62
2. We have reviewed your response to comment 6 and note that your
presentation of wholesale sales by product category remains inclusive
of inter-company
sales. Please ensure that you disclose the amount of revenues from
external customers for
each product category. Show us what your proposed disclosure would
have looked like
for the historical periods presented. Refer to ASC 280-10-50-40 and
ASC 606-10-50-5.
You may contact Charles Eastman at 202-551-3794 or Andrew Blume at
202-551-3254
with any questions.
FirstName LastNameJ. Michael Daniel Sincerely,
Comapany NameBassett Furniture Industries Inc.
Division of
Corporation Finance
May 28, 2021 Page 2 Office of
Manufacturing
FirstName LastName