Skyline Corporation | ||
P.O. Box 743 (46515-0743) | ||
2520 ByPass Road | ||
Elkhart, Indiana 46514-1584 | ||
(574) 294-6521 | ||
February 6, 2015
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Attn: John Cash, Accounting Branch Chief
100 F Street, N.E.
Washington, D.C. 20549
Re: | Skyline Corporation |
Form 10-K for the Fiscal Year Ended May 31, 2014
Filed August 22, 2014
Definitive Proxy Statement on Schedule 14A
Filed August 29, 2014
File No. 001-04714
Dear Mr. Cash:
We have received your letter dated February 2, 2015 detailing your office’s review of the above-referenced filings. On behalf of Skyline Corporation (“Skyline” or the “Company”), below are our responses to those comments. For your convenience, I have reproduced your comments and requests for information in bold below followed by our responses in regular type.
* * * * *
Definitive Proxy Statement on Schedule 14A
Retirement Benefits, page 15
1. We note that you have entered into retirement benefit arrangements with your named executive officers and that you reference a Supplemental Retirement Benefits Plan. Please file such arrangements as exhibits to your future Exchange Act filings. See Item 601(b)(10)(iii) of Regulation S-K.
Response: As requested, the Company will file the Supplemental Retirement Benefits Plan arrangements as exhibits to the Company’s future Exchange Act filings.
* * * * *
On behalf of the Company, I hereby acknowledge in connection with the responses contained in this letter that:
• | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
• | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
• | the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
U.S. Securities and Exchange Commission
February 6, 2015
Page 2 of 2
We appreciate your review of our responses to your comments. Should you have additional comments or questions, please contact me at (574) 350-2275.
Sincerely, |
/s/ Jon S. Pilarski |
Jon S. Pilarski |
Chief Financial Officer |
cc: | Scott R. Troeger, Esq. |
David P. Hooper, Esq.