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United States securities and exchange commission logo
April 8, 2022
D. Andrew Edwards
Chief Financial Officer
TREDEGAR CORP
1100 Boulders Parkway
Richmond, VA 23225
Re: TREDEGAR CORP
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed March 11,
2022
File No. 001-10258
Dear Mr. Edwards:
We have limited our review of your filing to the financial
statements and related
disclosures 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, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 19
1. We note your prolific
use of non-GAAP measures in your discussion of your results of
operations with little
to no discussion of your GAAP measures of profitability, such as
Net Income. We also
note that elsewhere in your document you discuss the impact of
events on EBITDA, such
as the customer product transition in your surface protection
business, without
disclosing the actual and expected impact on Net Income. In future
filings beginning with
your next quarterly report, please revise to also include discussions
of the most directly
comparable GAAP measures with equal or greater prominence. Refer
to the Compliance and
Disclosure Interpretations for Non-GAAP Financial Measures,
including Question
102.10, for guidance.
D. Andrew Edwards
FirstName LastNameD. Andrew Edwards
TREDEGAR CORP
Comapany
April NameTREDEGAR CORP
8, 2022
April 28, 2022 Page 2
Page
FirstName LastName
Financial Statements
Note 12 - Income Taxes, page 67
2. We note significant changes in the amount of deferred tax assets you
have recognized
at December 31, 2021 relating to pensions and NOL and credit
carryforwards. Please tell
us, and disclose in future filings, the drivers behind the significant
changes in the
components of your deferred tax assets.
In closing, 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 Kevin Stertzel at (202) 551-3723 or Martin James at (202)
551-
3671 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing