United States securities and exchange commission logo
May 7, 2020
Daniel Bernstein
President, Chief Executive Officer and Director
Bel Fuse Inc.
206 Van Vorst Street
Jersey City, New Jersey 07302
Re: Bel Fuse Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed March 25,
2020
File No. 001-11676
Dear Mr. Bernstein:
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 year ended December 31, 2019
Consolidated Financial Statements
3. Revenue, page 43
1. We note your
disclosures under Consignment that certain customers operate under a type
of concession agreement
whereby you ship goods to a warehouse or hub, where the goods
will be pulled by the
customer at a later date. We also note that under ASC 606 you
determined control
transfers to the customer upon either delivery from your warehouse, or
arrival at the hub,
depending on the applicable shipping terms, and revenue is recognized
as control is
transferred (at the time product is shipped to the hub). Please more fully
address the following:
Daniel Bernstein
Bel Fuse Inc.
May 7, 2020
Page 2
Explain how you determined control of your products transfers to
a customer when
products are shipped to a hub and address each indicator of
transfer of control in ASC
606-10-25-30. Specifically explain how and why you determined the
majority of
hubs are "customer-controlled" and therefore control of products
has transferred to
the customer;
Explain the reasons why you and your customers utilize these type
of concession
agreements. Specifically address the range of time between when
you ship products
to a hub and when the products are pulled by the customer;
Based on your identification of these agreements as Consignments,
explain how you
considered the provisions in ASC 606-10-55-79 and 80; and
Although these agreements are not typical bill and hold
arrangements, since it
appears billing for products only occurs after the customer
obtains physical
possession, explain if and how you considered the provisions in
ASC 606-10-55-83
and 84, including whether you may be providing custodial services
that should be
identified as a separate performance obligation.
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 Andi Carpenter at 202-551-3645 or Anne McConnell at
202-551-3709
with any questions.
FirstName LastNameDaniel Bernstein Sincerely,
Comapany NameBel Fuse Inc.
Division of
Corporation Finance
May 7, 2020 Page 2 Office of
Manufacturing
FirstName LastName