SEC Comment Letter for EQUIFAX INC (EFX) (CIK 0000033185) (EFX) — Sep 7, 2012
EQUIFAX INC (EFX) (CIK 0000033185)
Date: Sept. 7, 2012 · CIK: 0000033185 · Accession: 0000000000-12-048698
AI Filing Summary & Sentiment
File numbers found in text: 001-06605
Letter
September 7, 2012 Via E -mail Dean C. Arvidson Senior Vice President, Deputy General Counsel & Corporate Secretary Equifax Inc. 1550 Peachtree St. NW Atlanta, GA 30309
Re: Equifax Inc. Form 10-K for Fiscal Year Ended December 31, 2011 Filed February 23, 2012 File No. 001-06605
Dear Mr. Arvidson :
We have reviewed your filing an d have the following comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2011
Risk Factors, page 15
Security breaches and other disruptions to our information technology…, page 17
1. We note you disclose that disruptions to y our information technology networks and infrastructure may be vulnerable to damage, disruptions, or shutdowns due to various events, including cyber attacks and other security breaches. If you have experienced any cyber attacks, security breaches or other similar events in the past, in future filings, beginning with your next Form 10 -Q, please confirm that you will state that fact in order
Dean C. Arvidson Equifax Inc. September 7, 2012 Page 2
to provide the proper context for your risk factor disclosure. Please refer to the Division of Corporation Finance ’s Disclosure Guidance Topic No. 2 at http://www.sec.gov/divisions/corpfin/guidance/cfguidance -topic2.htm for additional information.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure 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 disclosure, they are responsible for the acc uracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of 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 Commissi on or any person under the federal securities laws of the United States.
You may contact Kenya Gumbs, Staff Accountant at 202-551-3373 or Robert Littlepage, Accounting Branch Chief, at 202-551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp, Attorney -Advisor, at 202-551-6971 or Kathleen Krebs, Special Counsel, at 202 -551-3350 with any other questions.
Sincerely,
/s/ Kathleen Krebs, for
Show Raw Text
September 7, 2012 Via E -mail Dean C. Arvidson Senior Vice President, Deputy General Counsel & Corporate Secretary Equifax Inc. 1550 Peachtree St. NW Atlanta, GA 30309 Re: Equifax Inc. Form 10-K for Fiscal Year Ended December 31, 2011 Filed February 23, 2012 File No. 001-06605 Dear Mr. Arvidson : We have reviewed your filing an d have the following comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2011 Risk Factors, page 15 Security breaches and other disruptions to our information technology…, page 17 1. We note you disclose that disruptions to y our information technology networks and infrastructure may be vulnerable to damage, disruptions, or shutdowns due to various events, including cyber attacks and other security breaches. If you have experienced any cyber attacks, security breaches or other similar events in the past, in future filings, beginning with your next Form 10 -Q, please confirm that you will state that fact in order Dean C. Arvidson Equifax Inc. September 7, 2012 Page 2 to provide the proper context for your risk factor disclosure. Please refer to the Division of Corporation Finance ’s Disclosure Guidance Topic No. 2 at http://www.sec.gov/divisions/corpfin/guidance/cfguidance -topic2.htm for additional information. We urge all persons who are responsible for the accuracy and adequacy of the disclosure 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 disclosure, they are responsible for the acc uracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of 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 Commissi on or any person under the federal securities laws of the United States. You may contact Kenya Gumbs, Staff Accountant at 202-551-3373 or Robert Littlepage, Accounting Branch Chief, at 202-551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp, Attorney -Advisor, at 202-551-6971 or Kathleen Krebs, Special Counsel, at 202 -551-3350 with any other questions. Sincerely, /s/ Kathleen Krebs, for Larry Spirgel Assistant Director