Commission File Number 0-5680
BURKE MILLS, INC.
IRS EMPLER IDENTIFICATION (56-0506342)
NORTH CAROLINA
191 Sterling Street, N.W.
Valdese, North Carolina 28690
(828) 874-6341
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
ATTENTION: Mr. Michael Moran
REF: SUPPLEMENTAL INFORMATION PER SEC LETTER OF DECEMBER 19, 2007
BURKE MILLS, INC.
FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2006
FILED APRIL 13, 2007
FILE NO. 000-05680
Dear Sirs:
The following supplemental information is being provided to you as follow up to
your December, 2007 letter from Michael Moran, Accounting Branch Chief. For
greater clarification, our comments follow each item in your letter and are
noted as "Burke's Response" and "Revised Disclosure Will Be As Follows".
Additionally, a company acknowledgement statement is attached (Attachment A) per
your guidelines.
FORM 10-k FOR THE FISCAL YEAR ENDED DECEMBER 31, 2006
General
1. We note that during our prior review of your January 1, 2005, Form 10-K that
responses to our comment letter dated July 8, 2005, were not uploaded to Edgar.
We reissue our request that you please file your response on Edgar.
Burke's Response:
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Our responses to the comment letter dated July 8, 2005 were filed on August 9,
2005 on Edgar as a supplement document instead of a correspondence file.
Critical Accounting Policies and Estimates, page 16
2. Please provide quantitative analysis with your discussion of critical
accounting policies. For example, you should disclose the period end balances of
liabilities associated with self funded employee claims and discuss any
significant additions and changes to the balances. With respect to inventory
reserves you should disclose the amount of reserves recorded at each balance
sheet date, additions to and utilization of the reserve for each period, and the
reasons for any significant changes.
Burke's Response:
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The Company will provide the above requested information in the next filing.
Statement of Operations, page 25
3. We note that commission revenue accounts for more than 10% of total revenues
in 2006. Please tell us why you have not presented sales separately for
commission revenues as it appears that you are providing a service rather than
selling tangible products. See Regulation S-X Rule 5-03(b).
Page 1 of 3
Burke's Response:
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The Company has viewed its operations as adding value to yarn whether the yarn
was purchased by the company or the customer.
The company will list commission sales separately on the next filing.
Notes Receivable, page 32
4. In future filings please revise your disclosures to include Schedule II -
Valuation and Qualifying Accounts. Please include in the schedule your reserves
activity, balances and additions, subtractions and adjustments, with regards to
your allowance for doubtful accounts and sales returns. We are aware a similar
comment was issued in a comment letter dated July 8, 2005, we are unable to
locate a response on Edgar or identify where in your current document you have
included this schedule. Reference is made to Regulation S-X 5-04(c).
Burke's Response:
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The Company had included Schedule II in its filing for year ended December 31,
2005. In the filing for year ended December 30, 2006 the Schedule II was omitted
because the balances were shown in other areas of the 10K. The Company will
include Schedule II in future filings.
Other Commitments, page 37
5. Please present a table showing year-end self-insurance reserve balances and
additions, subtractions and adjustments made during the year. You may provide
such information in the notes to your financial statements or as part of your
analysis of reserve accounts included in Schedule II.
Burke's Response:
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The Company will provide in future filings a table showing year-ended
self-insurance reserve balances and additions, subtractions and adjustments as
requested.
By:
/s/Humayun N. Shaikh Date: ____January 11, 2008__
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Humayun N. Shaikh
Chairman and CEO
/s/Thomas I. Nail Date: ____January 11, 2008__
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Thomas I. Nail
President and CFO
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ATTACHMENT A
BURKE MILLS, INC.
STATEMENT OF COMPLICANCE TO SEC FILINGS
AS REQUIRED UNDER THE SECURITIES ACT OF 1934
Burke Mills, Inc. acknowledges that it is responsible for the adequacy and
accuracy of disclosures in SEC filings, and further to ensure that filings
include all information required under the Securities Act of 1934 to provide all
information investors require for an informed investment decision.
Additionally, staff comments or changes to disclosures in response to staff
comments do not foreclose the SEC from taking any action with respect to
filings. And summarily, Burke Mills, Inc. may not assert staff comments as a
defense in any proceedings initiated the SEC or any person under the federal
securities laws of the United States.
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