SEC Comment Letter for BRINKS CO (BCO) (CIK 0000078890) (BCO) — Jun 17, 2015
BRINKS CO (BCO) (CIK 0000078890)
Date: June 17, 2015 · CIK: 0000078890 · Accession: 0000000000-15-032075
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File numbers found in text: 001-09148
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June 17, 2015 Joseph W. Dziedzi c Chief Financial Officer The Brink’s Company P.O. Box 18100 1801 Bayberry Court Richmond, VA 23226 -8100 Re: The Brink’s Company Form 10-K for Fiscal Year Ended December 31, 2014 Filed March 5, 2015 File No. 001-09148 Dear Mr. Dziedzi c: We have reviewed your filing an d have the following comments. In our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2014 Item 6. Selected Financial Data, page 19 1. We note your prese ntation of operating profit, income from continuing operations, and diluted EPS – continuing operations within the non -GAAP basis portion of your selected financial data. Please revise the titles of non -GAAP financial measures here and throughout the fili ng to reflect their adjusted nature to ensure that they are not confused with GAAP financial measures with the same or similar titles. Please refer to Item 10(e)(ii)(E) of Regulation S -K. Note 1: Summary of Significant Accounting Principles, page 69 2. We note per page 3 in your Business section that you incur costs when preparing to serve a new customer or to transition away from an existing customer. Please tell us the nature of these costs, the amount of costs incurred during the year ended December 31 , 2014, Joseph W. Dziedzi c The Brink’s Company June 17, 2015 Page 2 and how you account for such costs. If material, please provide your policy for the treatment of these costs. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing in cludes 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 accuracy and ade quacy 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 Commission or any perso n under the federal securities laws of the United States. You may contact Theresa Messinese at 202-551-3307 if you have questions regarding comments on the financial statements and related matters. You may also contact me at 202-551- 3380. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief