SEC Comment Letter for EQUIFAX INC (EFX) (CIK 0000033185) (EFX) — Feb 25, 2014
EQUIFAX INC (EFX) (CIK 0000033185)
Date: Feb. 25, 2014 · CIK: 0000033185 · Accession: 0000000000-14-009512
AI Filing Summary & Sentiment
Letter
Februar y 25, 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 February 20 , 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 Internal Controls Over Fina ncial Reporting 1. We have reviewed your response to comment 2. Because you did not identify or remediate the deficiency in Disclosure Controls and Procedures until after year end, it appears that Disclosure Controls and Procedures may not have been effective as of December 31, 2013. Please advise us. Further, please expand your proposed disclosure to explain the nature of the deficiency in more detail, when it occurred, when and how it was discovered, as well as how it was remediated.
Mr. Lee Adrean Equifax Inc. February 25, 2014 Page 2
2. With regard to the material weakness in Internal Control over Financial Reporting, please expand your proposed disclosure to clearly identify the nature of the material weakness, when it occurred and the circumstances leading to its discovery. You may co ntact 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 statements 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 25, 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 February 20 , 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 Internal Controls Over Fina ncial Reporting 1. We have reviewed your response to comment 2. Because you did not identify or remediate the deficiency in Disclosure Controls and Procedures until after year end, it appears that Disclosure Controls and Procedures may not have been effective as of December 31, 2013. Please advise us. Further, please expand your proposed disclosure to explain the nature of the deficiency in more detail, when it occurred, when and how it was discovered, as well as how it was remediated. Mr. Lee Adrean Equifax Inc. February 25, 2014 Page 2 2. With regard to the material weakness in Internal Control over Financial Reporting, please expand your proposed disclosure to clearly identify the nature of the material weakness, when it occurred and the circumstances leading to its discovery. You may co ntact 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 statements 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