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United States securities and exchange commission logo
October 11, 2022
Stephen Nolan
Chief Financial Officer and Treasurer
Albany International Corp.
216 Airport Drive
Rochester, New Hampshire 03867
Re: Albany
International Corp.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 25,
2022
File No. 001-10026
Dear Stephen Nolan:
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 the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Measures, page 36
1. We note that you
reconcile EBITDA and Adjusted EBITDA to operating income (loss) for
each segment and on a
consolidated basis. Please revise your presentation in future annual
and quarterly filings
to reconcile these non-GAAP measures to net income (loss), the most
directly comparable
GAAP measure. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and
Question 103.02 of the
SEC s Division of Corporation Finance C&DIs on Non-GAAP
Measures. This comment
also applies to your earnings releases furnished on Form 8-K.
2. We note that your
Adjusted EBITDA non-GAAP measure includes an adjustment for
foreign currency
revaluation (gains)/losses. Please tell us how you considered Question
100.01 of the SEC s
Division of Corporation Finance C&DIs on Non-GAAP Measures
given that such gains
and losses appear to reflect normal business activities of an entity
Stephen Nolan
Albany International Corp.
October 11, 2022
Page 2
with foreign subsidiaries/operations.
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 Dale Welcome at 202-551-3865 or Kevin Stertzel at
202-551-3723 with
any questions.
FirstName LastNameStephen Nolan Sincerely,
Comapany NameAlbany International Corp.
Division of
Corporation Finance
October 11, 2022 Page 2 Office of
Manufacturing
FirstName LastName