United States securities and exchange commission logo
November 18, 2021
Leanne Cunningham
Chief Financial Officer
Brown-Forman Corporation
850 Dixie Highway
Louisville, Kentucky 40210
Re: Brown-Forman
Corporation
Form 10-K for the
Fiscal Year Ended April 30, 2021
Filed June 21, 2021
File No. 001-00123
Dear Ms. Cunningham:
We have reviewed your November 15, 2021 response to our comment
letter and have the
following comment.
Please respond to this comment 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
comment apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment, we may have
additional comments. Our
reference to prior comment is to comment in our November 2, 2021 letter.
Form 10-K for the Fiscal Year Ended April 30, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
31
1. We note your response
to prior comment 1. The adjustment for estimated net change in
distributor inventories
appears to change the recognition method of your GAAP
measures from a sell-in
approach to a sell-through approach, and therefore, appears to
substitute individually
tailored recognition and measurement methods for those of GAAP.
Please remove this
adjustment from future filings or explain why you do not believe it
represents a tailored
accounting measure.
Leanne Cunningham
FirstName LastNameLeanne
Brown-Forman Corporation Cunningham
Comapany 18,
November NameBrown-Forman
2021 Corporation
November
Page 2 18, 2021 Page 2
FirstName LastName
You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or
Andrew
Blume, Staff Accountant, at 202-551-3254 with any questions.
Sincerely,
Division of Corporation
Finance
Office of Manufacturing