United States securities and exchange commission logo
February 3, 2021
Paul A. Rode
Chief Financial Officer and Treasurer
BellRing Brands, Inc.
2503 S. Hanley Road
St. Louis, Missouri 63144
Re: BellRing Brands,
Inc.
Form 10-K for the
Fiscal Year Ended September 30, 2020
Filed November 20,
2020
File No. 001-39093
Dear Mr. Rode:
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 September 30, 2020
Financial Statements
Notes to Financial Statements, page 56
1. Please enhance your
disclosure in future filings to include a discussion of your internal
structure, how you are
organized, and whether operating segments have been aggregated.
Refer to ASC
280-10-50-21.
Exhibits 31
Section 302 Certifications, page 81
2. The certifications
filed as Exhibits 31.1, 31.2 and 31.3 do not include the introductory
language in paragraph 4
and paragraph 4(b) referring to internal control over financial
reporting as shown in
Item 601(b)(31) of Regulation S-K. Please file an amendment to
your Form 10-K to
include the correct certifications. In your amendment, you may
include the cover page,
explanatory note, signature page, and paragraphs 1, 2, 4 and 5 of
Paul A. Rode
BellRing Brands, Inc.
February 3, 2021
Page 2
Section 302 certifications. Please ensure that the revised
certifications refer to the Form
10-K/A and are currently dated. Refer to Regulation S-K Compliance &
Disclosure
Interpretation 246.13.
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 Andi Carpenter at 202-551-3645 or Jeff Gordon at
202-551-3866 with
any questions.
FirstName LastNamePaul A. Rode Sincerely,
Comapany NameBellRing Brands, Inc.
Division of
Corporation Finance
February 3, 2021 Page 2 Office of
Manufacturing
FirstName LastName
