April 1, 2020
Stephanie M. Risk-McElroy
President and Chairman of the Board
George Risk Industries, Inc.
802 South Elm St.
Kimball, Nebraska 69145
Re: George Risk Industries, Inc.
Form 10-K for the Fiscal Year Ended April 30, 2019
Filed August 13, 2019
Amendment No. 1 to Form 10-K for the Fiscal Year Ended April 30,
2019
Filed March 25, 2020
File No. 000-05378
Dear Ms. Risk-McElroy:
We have reviewed the amendments to your filings 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
comments in our
March 4, 2020 letter.
Amendment No 1 to Form 10-K for the Fiscal Year Ended April 30, 2019
Item 8. Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2
1. We note changes to Notes 3, 6, 8 and 13, and the emphasis of a matter
paragraph that
references Note 13. However, the audit report is dual dated as of "August
13, 2019,
except for Note 3, for which the date is March 23, 2020." Please further
amend the Form
10-K to have your auditors include an audit report that is correctly
dated to reflect their
audit of the restated financial statements. Refer to PCAOB Auditing
Standard 3110.
Stephanie M. Risk-McElroy
FirstName LastNameStephanie M. Risk-McElroy
George Risk Industries, Inc.
Comapany NameGeorge Risk Industries, Inc.
April 1, 2020
Page 1,
April 2 2020 Page 2
FirstName LastName
Notes to Financial Statements
8. Income Taxes, page F-21
2. Please revise the reconciliation of income taxes with Federal and
State taxable income to
foot correctly.
13. Correction of Previously Issued Financial Statements, page F-25
3. We note that you adopted ASU 2016-01 as of May 1, 2018 but that you
recorded the one-
time adjustment to retained earnings to reclassify the accumulated
other comprehensive
gain related to unrealized gains on equity securities as of April 30,
2019. Further, we note
from your amended Forms 10-Q that no changes were made to your fiscal
year 2019
interim financial statements. Please address the following:
Provide us with your supporting calculation of the $2,424,000
adjustment to Other
comprehensive income and retained earnings as a result of the
adoption of ASU
2016-01 and explain how the amount reconciles to the net
unrealized gains disclosed
in the tables in Note 3.
Explain to us how you have complied with the adoption guidance in
ASU 2016-01
which states that an entity should apply the amendments by means
of a cumulative-
effect adjustment to the balance sheet as of the beginning of the
fiscal year of
adoption, or revise to comply.
Tell us how you applied the accounting guidance in ASU 2016-01
during the
interim periods in the fiscal year beginning May 1, 2018 and
ending April 30, 2019,
or revise to apply the guidance.
4. Further amend the filing to comply fully with the requirements of ASC
250-10-50-07
through 10 in presenting the restated financial statements and related
disclosure.
Please address the following:
Label all changed columns or captions to your primary financial
statements as well as
to the notes to financial statements "As Restated."
State clearly in this note that your previously issued financial
statements have been
restated.
Disclose the effect of the correction on each financial statement
line item and any
per-share amounts affected for each prior period presented. Refer
to the examples in
ASC 250-10-50-55 for further guidance.
Disclose the cumulative effect of the correction on retained
earnings or other
appropriate components of equity or net assets in the statement
of financial position
as of the beginning of the earliest period presented.
This comment also applies to your Forms 10-Q for the quarterly periods
ended July 31,
2019 and October 31, 2019.
Stephanie M. Risk-McElroy
George Risk Industries, Inc.
April 1, 2020
Page 3
5. Revise the filing to present all earnings per share amounts to the
nearest cent (i.e., only
two decimal points) so as not to imply a greater level of precision
than exits.
You may contact Andi Carpenter at 202-551-3645 or Martin James, Senior
Advisor, at
202-551-3671 with any questions.
FirstName LastNameStephanie M. Risk-McElroy Sincerely,
Comapany NameGeorge Risk Industries, Inc.
Division of
Corporation Finance
April 1, 2020 Page 3 Office of
Manufacturing
FirstName LastName