SEC Comment Letter for OMNICOM GROUP INC. (OMC) (CIK 0000029989) (OMC) — Mar 29, 2016
OMNICOM GROUP INC. (OMC) (CIK 0000029989)
Date: March 29, 2016 · CIK: 0000029989 · Accession: 0000000000-16-070012
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File numbers found in text: 001-10551
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Mail Stop 3720 March 29, 2016 Mr. Philip J. Angelastro Chief Financial Officer Omnicom Group Inc. 437 Madison Avenue New York, NY 10022 Re: Omnicom Group, Inc. Form 10 -K for Fiscal Year Ended December 31, 201 5 Filed February 9, 2016 File No. 001-10551 Dear Mr. Angelastro : We have reviewed your filing and have the following comment. Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances , please tell us why in your response. After reviewing your response to th is comment, we may have additional comments. Consolidated Statements of Income , page F -5 1. Please revise your income statement presentation to fully comply with the line item requirements of Rule 5 -03 of Regulation S -X. We urge all persons who are responsible for the accuracy and adequacy of the disclos ure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclos ure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment, please provide a written statement from the company acknowledging that: Mr. Philip J. Angelastro Omnicom Group Inc. March 29, 2016 Page 2 the company is responsible for the adequacy and accuracy o f the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert S. Littlepage, Accountant Branch Chief at (202) 551 -3361 if you have questions regarding the comment on the financial statements and related matters. Please contact Greg ory Dundas, Attorney -Advisor at (202) 551 -3436 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spirgel Assistant Director AD Office 11 – Telecommunications