United States securities and exchange commission logo
July 1, 2022
Christopher May
Chief Financial Officer
American Axle & Manufacturing Holdings, Inc.
One Dauch Drive
Detroit, MI 48211-1198
Re: American Axle &
Manufacturing Holdings, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Response Dated June
3, 2022
File No. 001-14303
Dear Mr. May:
We have reviewed your June 3, 2022 response to our comment letter
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
May 23, 2022 letter.
Response Dated June 3, 2022
Risk Factors, page 11
1. We note your response
to comment 2. Tell us how you considered disclosing other
transition risks
related to climate change, including those noted in our prior comment, and
explain how you
evaluated the materiality of their effects on your business, financial
condition, and results
of operations.
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
22
2. We note your response
to comment 7 and reissue in part. Please provide quantitative
information for each of
the periods covered by your Form 10-K to substantiate your
conclusion that weather
related damages to your property or operations were determined
Christopher May
American Axle & Manufacturing Holdings, Inc.
July 1, 2022
Page 2
not to be material.
Please contact Patrick Fullem at (202) 551-8337 or Sergio Chinos at
(202) 551-7844 with
any questions.
Sincerely,
FirstName LastNameChristopher May
Division of Corporation
Finance
Comapany NameAmerican Axle & Manufacturing Holdings, Inc.
Office of Manufacturing
July 1, 2022 Page 2
cc: Robert D. Giannattasio
FirstName LastName
