SEC Comment Letter for EQUIFAX INC (EFX) (CIK 0000033185) (EFX) — Oct 1, 2013
EQUIFAX INC (EFX) (CIK 0000033185)
Date: Oct. 1, 2013 · CIK: 0000033185 · Accession: 0000000000-13-054116
AI Filing Summary & Sentiment
Letter
October 1 , 2013 Via E-mail Mr. Lee Adrean Corporate Vice President & Chief Financial Officer Equifax Inc. 1550 Peachtree Street, N.W. Atlanta, Georgia 30309
Re: Equifax Inc. Form 10-K for the Fis cal Year Ended December 31, 2012 Filed February 22, 2013 Response dated September 26, 2013 File No. 001 -06605
Dear Mr. Adrean :
We have reviewed your response and have the following comment . Please provide us with the requested information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appli es to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to our comment, we may have additional comments.
Form 10 -K for the Year Ended December 31 , 2012 Goodwill and Other Intangib le Assets, page 73 Indefinite -Lived Intangible Assets, page 74 1. We note your response to comment two. It appears that the reacquired territorial rights should have been valued and amortized over the remaining contractual term, regardless of potential renew als, in accordance with ASC 805 -20-30-20 and 35 -2. Please revise or advise us.
Mr. Lee Adrean Equifax Inc. October 1 , 2013 Page 2
You may contact Kenya Wright Gumbs, Staff Accountant, at (202) 551 -3373 or Robert S. Littlepage , Accountant Branch Chief, at (202) 551 -3361, if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Li ttlepage for
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October 1 , 2013 Via E-mail Mr. Lee Adrean Corporate Vice President & Chief Financial Officer Equifax Inc. 1550 Peachtree Street, N.W. Atlanta, Georgia 30309 Re: Equifax Inc. Form 10-K for the Fis cal Year Ended December 31, 2012 Filed February 22, 2013 Response dated September 26, 2013 File No. 001 -06605 Dear Mr. Adrean : We have reviewed your response and have the following comment . Please provide us with the requested information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appli es to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to our comment, we may have additional comments. Form 10 -K for the Year Ended December 31 , 2012 Goodwill and Other Intangib le Assets, page 73 Indefinite -Lived Intangible Assets, page 74 1. We note your response to comment two. It appears that the reacquired territorial rights should have been valued and amortized over the remaining contractual term, regardless of potential renew als, in accordance with ASC 805 -20-30-20 and 35 -2. Please revise or advise us. Mr. Lee Adrean Equifax Inc. October 1 , 2013 Page 2 You may contact Kenya Wright Gumbs, Staff Accountant, at (202) 551 -3373 or Robert S. Littlepage , Accountant Branch Chief, at (202) 551 -3361, if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Li ttlepage for Larry Spirgel Assistant Director