Bankruptcy: DIEBOLD NIXDORF, Inc

Form Type: CORRESP

Filing Date: 2024-10-18

Corporate Action: Bankruptcy

Type: Update

Accession Number: 000002882324000102

Filing Summary: On October 18, 2024, Diebold Nixdorf, Incorporated submitted a correspondence letter to the SEC addressing comments from the SEC staff regarding their annual report for the fiscal year ended December 31, 2023. The company acknowledged previous comments about the presentation of non-GAAP financial measures and confirmed their intention to continue presenting combined financials for the predecessor and successor periods following their emergence from bankruptcy in August 2023. Management emphasized that a mid-month emergence from bankruptcy poses challenges in financial reporting and that combined presentations provide more meaningful insights for investors by evaluating core performance. The letter also provided detailed responses related to management's discussion and analysis (MD&A) to clarify the implications of their bankruptcy on future financial reporting.

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Form Type: CORRESP

Filing Date: 2024-09-26

Corporate Action: Bankruptcy

Type: Update

Accession Number: 000002882324000099

Filing Summary: Diebold Nixdorf, Incorporated submitted a correspondence letter in response to comments from the SEC regarding its Form 10-K for the fiscal year ended December 31, 2023. The company acknowledged its application of fresh-start accounting following its emergence from bankruptcy, resulting in significant non-cash adjustments to asset valuations. The company detailed adjustments including an increase in finished goods by $39.1 million, tangible assets by $46.2 million, and intangible assets by $320.0 million. The adjustments also noted additional costs related to sales and depreciation resulting from these increased asset valuations. The company plans to revise future filings to present GAAP results for both predecessor and successor periods distinctly without adjustments, and will disclose impacts of ASC 852 on financial operations. Additionally, the company will file its clawback policy as an exhibit in its upcoming 10-K for 2024. The correspondence also addressed the restructuring costs incurred during significant financial distress, clarifying these are not normal operating expenses. Future disclosures will avoid presenting potentially misleading non-GAAP measures of segment operating profit.

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