CORRESP: Correspondence
Published on
Direct dial: (213) 576-2467
E-mail: krustand@rsac.com
E-mail: krustand@rsac.com
January 17, 2008
VIA OVERNIGHT COURIER
United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, DC 20549
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, DC 20549
| Attn: | Daniel Morris, Attorney Advisor Mail Stop 3561 |
|||||
| Re: | Reliance Steel & Aluminum Co. | |||||
| Definitive 14A Proxy Statement; Filed April 12, 2007 | ||||||
| File No. 001-13122 | ||||||
Ladies and Gentlemen:
We are in receipt of your letter dated December 21, 2007 to David H. Hannah, Chief Executive
Officer, regarding your review of the above-referenced proxy statement filed by Reliance Steel &
Aluminum Co. (“Reliance”), as well as our October 2, 2007 response to your comment letter dated
August 21, 2007. Our response to your additional comments is as follows:
1. Reliance intends to comply with your comments in future filings to the extent that they are
applicable and consistent with the disclosure requirements set forth in the Securities Exchange Act
of 1934, as amended, and the rules promulgated thereunder. In this regard, please note that the
Compensation and Stock Option Committee annually considers whether to amend the Key-Man Incentive
Bonus Plan or other aspects of the compensation of executive officers.
2. In response to your re-issued comments 4 and 7 and our conversation on January 11, 2008, we
understand that you are not requiring us to further revise the Compensation Disclosure and Analysis
for 2007, but that we confirm that we will comply with such comments in future filings. We do so
confirm. As requested, we intend to provide a greater analysis of specific factors considered by
the Compensation and Stock Option
| Page 2 | January 17, 2008 | |
| U.S. Securities and Exchange Commission | ||
| Attn: Daniel Morris, Attorney Advisor |
Committee for each of the named executive officers in making
compensation decisions and the reasons that the Committee believes the amounts paid to be
appropriate.
Should you have any additional questions or comments, please feel free to contact me.
| Sincerely yours, | ||
| /s/ Kay Rustand Vice President and General Counsel |
KR/dr
cc:
|
David H. Hannah | |
| Karla Lewis | ||
| Compensation and Stock Option Committee Members | ||
| Kathleen Kerrigan | ||
| Carlos Pacho, Sr. Assistant Chief Accountant | ||
| Kevin Hands | ||
| David Mittelman, Sr. Staff Attorney |