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United States securities and exchange commission logo
April 21, 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
File No. 000-00209
Dear Mr. Daniel:
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 November 28, 2020
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Analysis of Operations, page 17
1. 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
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.
Refer to Item 303(a)
and (b) of Regulation S-K and SEC Release No. 33-8350.
2. We note that the
"Income (loss) from operations" amounts in the "Consolidated" column
J. Michael Daniel
FirstName LastNameJ. Michael
Bassett Furniture Industries Inc. Daniel
Comapany
April NameBassett Furniture Industries Inc.
21, 2021
April 221, 2021 Page 2
Page
FirstName LastName
of the tables on pages 19 and 20 appear to be non-GAAP measures. We
further note that
these amounts are reconciled to GAAP income on page 21 using a
different line item
description. In future filings, please ensure you clearly identify
these amounts as non-
GAAP measures and that they are not presented using a GAAP line item
description.
3. We note that you present gross profit and gross profit margin for your
wholesale and retail
reportable segments. Considering gross profit is not the segmental
measure of profit or
loss you present under ASC 280-10-50-22 and the figures are inclusive
of inter-company
amounts, these gross profit and gross profit margin amounts appear to
represent non-
GAAP measures. Accordingly, please revise future filings to comply
with all non-GAAP
rules, including, but not limited to, a presentation of and
reconciliation to the most directly
comparable GAAP measures. Show us what your revised disclosure would
have looked
like for the historical periods presented. See Item 10(e) of
Regulation S-K.
Consolidated Statements of Operations, page 32
4. We note that your logistics net sales revenues exceeded 10% of your
consolidated net
sales for each fiscal year presented and further note your disclosure
on page 62 that Zenith
Freight Lines operating costs are included in selling, general and
administrative expenses.
In future filings, please ensure you comply with Rule 5-03(b)(2) of
Regulation S-X to
provide separate disclosure of cost of services on your consolidated
statement of
operations.
Notes to Consolidated Financial Statements
18. Segment Information, page 62
5. We note that the net sales disclosed for your reportable segments are
inclusive of inter-
company sales. Please revise your presentation in future filings to
disclose revenues from
external customers for each reportable segment as required by ASC
280-10-50-22(a).
Show us what your revised net sales disclosures would have looked like
for the historical
periods presented. Also see the illustrative examples in ASC
280-10-55-48 and 55-49.
6. We note that you provide a breakdown of wholesale sales by product
category and that the
amounts are inclusive of inter-company sales. Please revise future
filings to disclose
consolidated sales from external customers for each product and
service or each group of
similar products and services. See ASC 280-10-50-40.
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.
J. Michael Daniel
Bassett Furniture Industries Inc.
April 21, 2021
Page 3
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
April 21, 2021 Page 3 Office of Manufacturing
FirstName LastName