SEC Comment Letter for AUTOMATIC DATA PROCESSING INC (ADP) (CIK 0000008670) (ADP) — Mar 6, 2020
AUTOMATIC DATA PROCESSING INC (ADP) (CIK 0000008670)
Date: March 6, 2020 · CIK: 0000008670 · Accession: 0000000000-20-002035
AI Filing Summary & Sentiment
File numbers found in text: 001-05397
Letter
March 5, 2020 Kathleen Winters Chief Financial Officer Automatic Data Processing, Inc. ADP Boulevard Roseland, NJ 07068 Re:Automatic Data Processing, Inc. Form 10-K for the Year Ended June 30, 2019 Filed August 9, 2019 File No. 001-05397 Dear Ms. Winters: We have reviewed your filing 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 Year Ended June 30, 2019 Note 16. Financial Data by Segment and Geographic Area, page 83 1.Please identify your operating segments (presumably, your "strategic business units") and tell us how they were determined. Refer to the guidance in ASC 280-10-50-1 through 9. In this regard, it appears from your website that there may be segment managers responsible for business units based on account (market) size and location (i.e. Small Business Solutions, National Account Services, Major Account Services, ADP Canada, and Employer Services International). Please provide us an organizational chart to help us understand how you are organized and identify for us your segment managers. 2.We note that you aggregate your strategic business units into two reportable segments based upon similar economic and operational characteristics. Please explain how these business units were aggregated into the Employee Service and PEO segments. Tell us more in detail how such business units are similar in economic and various respects pursuant to ASC 280-10-50-11.
FirstName LastNameKathleen Winters Comapany NameAutomatic Data Processing, Inc. March 5, 2020 Page 2 FirstName LastName Kathleen Winters Automatic Data Processing, Inc. March 5, 2020 Page 2 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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters or with any other questions. Sincerely, Division of Corporation Finance Office of Technology
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March 5, 2020
Kathleen Winters
Chief Financial Officer
Automatic Data Processing, Inc.
ADP Boulevard
Roseland, NJ 07068
Re:Automatic Data Processing, Inc.
Form 10-K for the Year Ended June 30, 2019
Filed August 9, 2019
File No. 001-05397
Dear Ms. Winters:
We have reviewed your filing 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 Year Ended June 30, 2019
Note 16. Financial Data by Segment and Geographic Area, page 83
1.Please identify your operating segments (presumably, your "strategic business units") and
tell us how they were determined. Refer to the guidance in ASC 280-10-50-1 through 9.
In this regard, it appears from your website that there may be segment managers
responsible for business units based on account (market) size and location (i.e. Small
Business Solutions, National Account Services, Major Account Services, ADP Canada,
and Employer Services International). Please provide us an organizational chart to help us
understand how you are organized and identify for us your segment managers.
2.We note that you aggregate your strategic business units into two reportable segments
based upon similar economic and operational characteristics. Please explain how these
business units were aggregated into the Employee Service and PEO segments. Tell us
more in detail how such business units are similar in economic and various respects
pursuant to ASC 280-10-50-11.
FirstName LastNameKathleen Winters
Comapany NameAutomatic Data Processing, Inc.
March 5, 2020 Page 2
FirstName LastName
Kathleen Winters
Automatic Data Processing, Inc.
March 5, 2020
Page 2
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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters or with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology