United States securities and exchange commission logo
September 22, 2022
Ted Fernandez
Chief Executive Officer and Chairman of the Board
The Hackett Group, Inc.
1001 Brickell Bay Drive, Suite 3000
Miami, Florida 33131
Re: The Hackett Group,
Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed March 4, 2022
Response dated
September 6, 2022
File No. 333-48123
Dear Mr. Fernandez:
We have reviewed your September 6, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to the oral
comments we conveyed on August 17, 2022.
Form 10-K for Fiscal Year Ended December 31, 2021
Financial Statements
Note 1. Basis of Presentation and General Information
Segment Reporting , page 42
1. We read your response
to comment 1. We have objected to your conclusion that you have
one operating segment
and one reportable segment. This represents an error in previously
issued financial
statements, as defined in ASC 250-10-20. Please provide us with a
detailed analysis
explaining how you evaluated the materiality of this error on your
financial statements
and related disclosures for all periods presented. Also, separately
address in detail how
this error impacted your conclusions regarding the effectiveness of
your disclosure
controls and procedures and your internal control over financial reporting.
Ted Fernandez
The Hackett Group, Inc.
September 22, 2022
Page 2
Finally, provide us with the disclosures you plan to provide in your
periodic reports with
respect to this error.
2. Your response to comment 1 indicates that you plan to change to three
reportable
segments (SB&T-US, EEA and International) beginning in the third
quarter of
2022. Please provide us with a detailed analysis of how you determined
your new
operating and reportable segments pursuant to ASC 280. As part of
this, describe any
changes to the structure of the organization and how the CODM will
manage the business,
including the segment measure of profitability that the entity will
utilize. Explain how
your CODM will allocate resources and assess performance. Tell us how
your budgeting
process will be conducted, the organization levels that budget to
actual results will be
presented for budget monitoring purposes throughout the year and the
frequency of your
CODM s budget monitoring process. Explain what financial information
will be provided
to your Board, including the organization levels at which it will be
presented and the
frequency it will be provided. Furthermore, provide us with sample
disclosures showing
what you plan to disclose in the segment footnote of your upcoming
Form 10-Q.
You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker at (202)
551-3769, if
you have any questions.
FirstName LastNameTed Fernandez Sincerely,
Comapany NameThe Hackett Group, Inc.
Division of
Corporation Finance
September 22, 2022 Page 2 Office of Trade
& Services
FirstName LastName