United States securities and exchange commission logo
August 25, 2020
Walter G. Borst
Chief Financial Officer
NAVISTAR INTERNATIONAL CORP
2701 Navistar Drive
Lisle, IL 60532
Re: NAVISTAR
INTERNATIONAL CORP
Form 10-K for the
Year Ended October 31, 2019
Filed December 17,
2019
Form 10-Q for the
Period Ended April 30, 2020
Filed June 4, 2020
File No. 001-09618
Dear Mr. Borst:
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-Q for the period ended April 30, 2020
Item 2. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations, page 45
1. We note that your
current discussion of changes in your results of operations includes a
discussion of the
factors responsible for the changes. However, it does not provide
adequate quantification
as to how each factor impacted your results of operations for the
periods presented. For
example, you state that certain changes were primarily attributed
to one factor or
partially offset by another factor. Where multiple factors impact a line
item in your financial
statements, please revise to quantify, where practical, how each
factor impacted your
reported results of operations in accordance with Item 303(a)(3) of
Regulation S-K and
Section III.D of Release No. 33-6835. In your response, please
provide us with an
example of the disclosure to be included in future filings based on
Walter G. Borst
NAVISTAR INTERNATIONAL CORP
August 25, 2020
Page 2
current results.
Critical Accounting Policies, page 57
2. On page 17, you disclose impairment triggers that resulted in
impairment charges.
On page 43, you disclose that the full severity and duration of the
related global economic
crisis is not known, but it is expected to continue to negatively
impact your operating
results and you expect the impacts of the COVID-19 pandemic on your
results to be more
significant in the third quarter and may continue until global
economic conditions
improve. Please tell us the material assumptions considered in your
most recent
impairment analysis for long-lived assets. Additionally, tell us if
you believe these
assumptions are reasonably likely to change for your third quarter in
fiscal 2020 as
compared to those used for the first half of fiscal 2020. Finally,
revise future filings to
provide disclosure required by ASC 275-10-50-8, as applicable.
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 Effie Simpson at (202) 551-3346 or Melissa Raminpour,
Branch Chief,
at (202) 551-3379 with any questions.
FirstName LastNameWalter G. Borst Sincerely,
Comapany NameNAVISTAR INTERNATIONAL CORP
Division of Corporation Finance
August 25, 2020 Page 2 Office of Manufacturing
FirstName LastName