Distribution Solutions Group, Inc. (DSGR)
CIK 703604 · EDGAR correspondence
| Date | Company | Type | Outcome | Issues |
|---|---|---|---|---|
| 2026-01-06 | Distribution Solutions Group, Inc. (DSGR) | SEC staff letter | Review completed (no further comments) | |
| 2025-12-30 | Distribution Solutions Group, Inc. (DSGR) | Company response | Agreed to revise | Non-GAAP: Equal ProminenceNon-GAAP: Reconciliation & UsefulnessICFR & Disclosure ControlsExhibits, Certifications & SignaturesFunds & BDCs (ASC 946, N-CSR) |
| 2025-12-18 | Distribution Solutions Group, Inc. (DSGR) | SEC staff letter | 2 staff comment(s) issued | Non-GAAP: Equal ProminenceNon-GAAP: Reconciliation & UsefulnessICFR & Disclosure ControlsExhibits, Certifications & SignaturesFunds & BDCs (ASC 946, N-CSR) |
Comments & responses
2025-12-18 · Form 10-K for Fiscal Year Ended December 31, 2024 Filed March 6, 2025 Form 8-K filed October 30, 2025 · Comment 1 · Management's Report on Internal Control over Financial Reporting, page 107 Agreed to revise
Staff comment: Please tell us why you omitted management’s assessment of the effectiveness of the registrant's internal control over financial reporting, including a statement as to whether or not internal control over financial reporting is effective. Refer to Item 308(a)(3) of Regulation S-K. Please also tell us why you omitted a statement that the registered public accounting firm that audited the financial statements included in this Form 10-K has issued an attestation report on your internal control over financial reporting. Refer to Item 308(a)(4) of Regulation S-K. letter →
Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in connection with management’s evaluation of the Company’s internal control over financial reporting as of the end of the period ending December 31, 2024, management concluded that as of such date, our internal control over financial reporting was effective. In addition, the registered public accounting firm that audited the financial statements included in our Form 10-K issued an attestation report that included an opinion that we maintained, in all material respects, effective internal control over financial reporting as of December 31, 2024, based on criteria established in the 2013 Internal Control – Integrated… response letter →
2025-12-18 · Form 10-K for Fiscal Year Ended December 31, 2024 Filed March 6, 2025 Form 8-K filed October 30, 2025 · Comment 2 · Exhibit 99.1, page 1 Agreed to revise
Staff comment: We note you reconcile adjusted EBITDA to net income, the most directly comparable GAAP measure. Your earnings release includes a table on page 1 and discussions on pages 1 and 2 of adjusted EBITDA without presenting or discussing the most directly comparable GAAP measure with equal or greater prominence. Please revise future disclosures to comply with Item 10(e)(1)(i)(A) of Regulation S-K or explain why a revision is not necessary. Refer to Questions 102.10(a) and 103.02 of the Staff’s Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. letter →
Company response: The Company respectfully acknowledges the Staff’s comment. The Company will include the most directly comparable GAAP measure with equal or greater prominence in future filings, beginning with the Company’s Form 8-K for the 4 th quarter 2025 earnings release. response letter →
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