SEC Comment Letter for EQUIFAX INC (EFX) (CIK 0000033185) (EFX) — May 11, 2010
EQUIFAX INC (EFX) (CIK 0000033185)
Date: May 11, 2010 · CIK: 0000033185 · Accession: 0000000000-10-026048
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File numbers found in text: 001-06605
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
May 11, 2010
Mr. Richard F. Smith Chairman and Chief Executive Officer Equifax Inc. 1550 Peachtree Street, N.W. Atlanta, GA 30309
RE: Equifax Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009
Filed February 23, 2010
Definitive Proxy Statement on Schedule 14A Filed March 24, 2010 File No. 001-06605
Dear Mr. Smith:
We have reviewed your filing and have the following comments. Please address the
following comments in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. If you disagree, we will consider your explanation as to why our comment is inapplicable or a future revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the Fiscal Year Ended December 31, 2009
Definitive Proxy Statement
1. We note your disclosure in response to Item 402(s) of Regulation S-K. Please describe the process you undertook to reach the conclusion that disclosure is not necessary.
* * * *
Mr. Richard F. Smith
Equifax Inc. May 11, 2010 Page 2
Please respond to these comments through correspondence over EDGAR within 10
business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors
require for an informed decision. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that
• the company is responsible for the adequacy and accuracy of the disclosure in the filings;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filings; 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. In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Division of Corporation Finance in our review of your filings or in response to our comments on your filings.
Please contact Scott Hodgdon, Attorney-Advisor, at (202) 551-3273, Kathleen Krebs,
Special Counsel, at (202) 551-3350, or me at (202) 551-3810 with any questions. S i n c e r e l y , L a r r y S p i r g e l A s s i s t a n t D i r e c t o r