Exhibit 18.1
Board of Directors
The Hillman Companies, Inc.
As stated in notes to the consolidated financial statements of The Hillman Companies, Inc. and
Subsidiaries (the
“Company”) for the year ended
December 31, 2007,
the Company changed the
date of its annual goodwill impairment test from the last day of the year to the first day
following the end of their 3
rd quarter. Management believes that the accounting
change is preferable in the circumstances because it better aligns the timing of
the Company’s
long-range planning with this test, as the impairment test is dependent on the results of the
Company’s long-range planning process. At your request, we have reviewed and discussed with
management the circumstances, business judgment, and planning that formed the basis for making
this change in accounting principle.
It should be recognized that professional standards have not been established for selecting
among alternative principles that exist in this area or for evaluating the preferability of
alternative accounting principles. Accordingly, we are furnishing this letter solely for
purposes of
the Company’s compliance with the requirements of the Securities and Exchange
Commission, and it should not be used or relied on for any other purpose.
Based on our review and discussion, we concur with management’s judgment that the newly
adopted accounting principle is preferable in the circumstances. In formulating this position,
we are relying on management’s business planning and judgment, which we do not find
unreasonable.
Very truly yours,
