SEC Comment Letter for EQUIFAX INC (EFX) (CIK 0000033185) (EFX) — Jun 10, 2015
EQUIFAX INC (EFX) (CIK 0000033185)
Date: June 10, 2015 · CIK: 0000033185 · Accession: 0000000000-15-030947
AI Filing Summary & Sentiment
File numbers found in text: 001-06605
Letter
June 10, 2015 John W. Gamble, Jr. Chief Financial Officer Equifax, Inc. 1550 Peachtree Street, N.W. Atlanta, Georgia 30309
Re: Equifax, Inc. Form 10 -K for Fiscal Year Ended December 31, 2014 Filed February 25, 2015 File No. 001-06605
Dear Mr. Gamble :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment . Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 8 -K filed March 22, 201 5
We note that your press release in Exhibit 99.1 discussed Adjusted EPS and Adjusted Operating Margin, but does not discuss equivalent GAAP financial measures. This presentation may attach undue prominence to the non -GAAP information . Please revise your presentation in future filings to show with equal or greater prominence, the most directly comparable financial measure or measures calculated and presented in accordance with GAAP . Please refer to Instruction 2 to Item 2.02 of Form 8 -K which states that certain provisions of Item 10(e) of Regulation S -K apply to disclosures under Item 2.02.
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 requir e. Since the company and its management are
Mr. John W. Gamble, Jr. Equifax, Inc. June 10, 2015 Page 2
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 responding to our comment, please provide a written sta tement 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 Commission or any person under the federal securities laws of the United States.
You may contact Inessa Kessman , Staff Accountant, at 202-551-3371 or Terry French , Accounting Branch Chief, at 202-551-3828 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Terry French for
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June 10, 2015 John W. Gamble, Jr. Chief Financial Officer Equifax, Inc. 1550 Peachtree Street, N.W. Atlanta, Georgia 30309 Re: Equifax, Inc. Form 10 -K for Fiscal Year Ended December 31, 2014 Filed February 25, 2015 File No. 001-06605 Dear Mr. Gamble : We have limited our review of your filing to the financial statements and related disclosures and have the following comment . Please comply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 8 -K filed March 22, 201 5 We note that your press release in Exhibit 99.1 discussed Adjusted EPS and Adjusted Operating Margin, but does not discuss equivalent GAAP financial measures. This presentation may attach undue prominence to the non -GAAP information . Please revise your presentation in future filings to show with equal or greater prominence, the most directly comparable financial measure or measures calculated and presented in accordance with GAAP . Please refer to Instruction 2 to Item 2.02 of Form 8 -K which states that certain provisions of Item 10(e) of Regulation S -K apply to disclosures under Item 2.02. 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 requir e. Since the company and its management are Mr. John W. Gamble, Jr. Equifax, Inc. June 10, 2015 Page 2 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 responding to our comment, please provide a written sta tement 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 Commission or any person under the federal securities laws of the United States. You may contact Inessa Kessman , Staff Accountant, at 202-551-3371 or Terry French , Accounting Branch Chief, at 202-551-3828 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Terry French for Carlos Pacho Senior Assistant Chief Accountant