SEC Comment Letter for EQUIFAX INC (EFX) (CIK 0000033185) (EFX) — Feb 12, 2014
EQUIFAX INC (EFX) (CIK 0000033185)
Date: Feb. 12, 2014 · CIK: 0000033185 · Accession: 0000000000-14-007662
AI Filing Summary & Sentiment
Letter
Februar y 12, 2014 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 January 27, 2014 File No. 001 -06605
Dear Mr. Adrean :
We have reviewed your response and have the following comment s. 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 s appl y to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to our comment s, 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 have reviewed your response to prior comment 4. While neither SFAS 141/142 nor EITF 04 -1 required a limit on the life of a reacquired right, it remains unclear why you believed it was reasonable to assume renewal of a right, and thereby an indefinite life, in instances where Equifax had the ability to terminate the contract at the end of its term, which, as you state in your response dated September 26, 2013, was generally the case for these older agreements. Please explain to us why it is reasonable of you to assume Equifax would renew the right after the contrac t period, once it was reacquired.
Mr. Lee Adrean Equifax Inc. February 12, 2014 Page 2
Internal Controls Over Financial Reporting 2. Please elaborate upon your response to our previous comment 3 so that we fully understand the process of your identification and remediation of the material weakness in internal controls over financial reporting. Include as part of your response a suffici ently detailed timeline that lays out your course of action. Specifically identify in this timeline when the weakness was identified, when management concluded the weakness was material, when a remediation plan was developed and implemented including its documentation, communication, and any testing. You may contact Kenya Wright Gumbs, Staff Accountant, at (202) 551 -3373 or Robert S. Littlepage Jr., Accountant Branch Chief, at (202) 551 -3361, if you have questions regarding comments on the financial state ments and related matters. Please contact me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage Jr., for
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Februar y 12, 2014 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 January 27, 2014 File No. 001 -06605 Dear Mr. Adrean : We have reviewed your response and have the following comment s. 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 s appl y to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to our comment s, 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 have reviewed your response to prior comment 4. While neither SFAS 141/142 nor EITF 04 -1 required a limit on the life of a reacquired right, it remains unclear why you believed it was reasonable to assume renewal of a right, and thereby an indefinite life, in instances where Equifax had the ability to terminate the contract at the end of its term, which, as you state in your response dated September 26, 2013, was generally the case for these older agreements. Please explain to us why it is reasonable of you to assume Equifax would renew the right after the contrac t period, once it was reacquired. Mr. Lee Adrean Equifax Inc. February 12, 2014 Page 2 Internal Controls Over Financial Reporting 2. Please elaborate upon your response to our previous comment 3 so that we fully understand the process of your identification and remediation of the material weakness in internal controls over financial reporting. Include as part of your response a suffici ently detailed timeline that lays out your course of action. Specifically identify in this timeline when the weakness was identified, when management concluded the weakness was material, when a remediation plan was developed and implemented including its documentation, communication, and any testing. You may contact Kenya Wright Gumbs, Staff Accountant, at (202) 551 -3373 or Robert S. Littlepage Jr., Accountant Branch Chief, at (202) 551 -3361, if you have questions regarding comments on the financial state ments and related matters. Please contact me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage Jr., for Larry Spirgel Assistant Director