Securities and Exchange Commission
March 18, 2013
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March 18, 2013
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attn: Jennifer Thompson, Accounting Branch Chief
| Re: | Belk, Inc. | |
| Form 10-K for Fiscal Year Ended January 28, 2012 | ||
| Filed on April 10, 2012 | ||
| File No. 000-26207 |
Dear Ms. Thompson:
We are responding to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its letter dated March 7, 2013. To assist in your review, we have included the Staff’s comment below prior to our response.
Form 10-K for the year ended January 28, 2012
Notes to Consolidated Financial Statements, page 34
(1) Summary of Significant Accounting Policies, page 34
Description of Business and Basis of Presentation, page 34
| 1. | We note your response to comment 1 from our letter dated February 1, 2013. In future filings, please separately quantify the impact of eCommerce sales on your comparable store sales percentages. |
Response to Comment 1:
In accordance with the Staff’s request, the Company will separately quantify the impact of eCommerce sales on our comparable store sales percentages in future filings.
The Company acknowledges that:
| • | it is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please do not hesitate to call the undersigned at (704) 426-8250 if you have any questions.
| Very truly yours, |
| /s/ Brian T. Marley |
| Brian T. Marley |
| Executive Vice President and Chief Financial Officer |
