United States securities and exchange commission logo
August 3, 2023
Bert Nappier
Executive Vice President and Chief Financial Officer
Genuine Parts Company
2999 Wildwood Parkway
Atlanta, GA 30339
Re: Genuine Parts
Company
Form 10-K for
Fiscal Year Ended December 31, 2022
Filed February 23,
2023
File No. 001-05690
Dear Bert Nappier:
We have reviewed your filing 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 Fiscal Year Ended December 31, 2022
Item 7. Management s Discussion and Analysis of Financial Condition
and Results of
Operations
Consolidated Results of Operations, page 19
1. You present total
segment profit and total segment margin that appear to be non-GAAP
financial measures in
MD&A. Please remove these non-GAAP measures or provide the
disclosures required by
Item 10(e) of Regulation S-K. Refer to Question 104.04 of the
Non-GAAP Financial
Measures Compliance and Disclosure Interpretations. This
comment also applies to
your Forms 10-Q filed in fiscal year 2023.
Non-GAAP Financial Measures, page 22
2. You record a tax impact
of adjustments representing 2.7% of the total adjustments made
in determining adjusted
net income as compared to the GAAP effective tax rate of 24.8%
in fiscal year 2022.
Please expand your disclosure to clarify how you determined the tax
Bert Nappier
Genuine Parts Company
August 3, 2023
Page 2
effect of non-GAAP adjustments in calculating the adjusted net income
and adjusted
diluted EPS in each reporting period presented. Refer to Question
102.11 of the Non-
GAAP Financial Measures Compliance and Disclosure Interpretations.
Consolidated Balance Sheet, page 36
3. Please state separately, in your balance sheet or in a note thereto,
any elements of prepaid
expenses and other current assets in excess of five percent of your
total current assets.
Refer to Rule 5-02(8) of Regulation S-X. In addition, please
separately state any elements
of other current liabilities in excess of five percent of your total
current liabilities. Refer
to Rule 5-02(20) of Regulation S-X.
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 Suying Li at (202) 551-3335 or Linda Cvrkel at (202)
551-3813 with
any questions.
FirstName LastNameBert Nappier Sincerely,
Comapany NameGenuine Parts Company
Division of
Corporation Finance
August 3, 2023 Page 2 Office of Trade
& Services
FirstName LastName