August 28, 2019
Via EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attention: Joel Parker
Re: Centric Brands Inc.
Form 10-K for Fiscal Year Ended December 31, 2018
Filed May 16, 2019
File No. 000-18926
Dear Mr. Parker:
On behalf of Centric Brands Inc. (the “Company,” “we,” “us” or “our”), reference is made to the verbal comment discussed with us on August 21, 2019 telephonically with you, a member of the staff of the Division of Corporate Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s Form 10‑K for the fiscal year ended December 31, 2018 filed with the Commission on May 16, 2019 (the “Annual Report”) and our previously filed response to the first comment letter filed with the Commission on July 25, 2019 (the “Response Letter”). For your convenience, a summary of the Staff’s comment is presented below in bold, italicized text below, with our response thereto set forth immediately under such comment.
Form 10‑K for Fiscal Year Ended December 31, 2018
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Adjusted Operating Cash Flow, page 41
1. | We acknowledge your response to comment 2 contained in the Response Letter. As GAAP requires you to present collections of sold receivables as cash flows from investing activities, it appears that your non-GAAP measure which includes them in cash flows from operating activities substitutes individually tailored recognition methods for those of GAAP. Please remove this non-GAAP measure. |
Response:
The Company accepts the Staff’s comment. In future filings, we will remove this disclosure.
T 646.839.7470
350 Fifth Avenue, 6th Floor, New York, NY 10118
www.centricbrands.com
If you have any questions or would like further information concerning the contents of this letter, please do not hesitate to contact me at 646‑839‑7470 or lnembirkow@centricbrands.com
Sincerely,
Lori Nembirkow
SVP, Legal & Compliance
cc:
Andrew Tarshis, Executive Vice President & General Counsel
Anurup Pruthi, Chief Financial Officer
Nazim Zilkha, Partner, Dechert LLP
Ravi Raghunathan, Partner, CohnReznick LLP
T 646.839.7470
350 Fifth Avenue, 6th Floor, New York, NY 10118
www.centricbrands.com