SEC Comment Letter for BRINKS CO (BCO) (CIK 0000078890) (BCO) — Aug 4, 2017
BRINKS CO (BCO) (CIK 0000078890)
Date: Aug. 4, 2017 · CIK: 0000078890 · Accession: 0000000000-17-027565
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 August 4, 2017 Ronald J. Domanico Executive Vice President and Chief Financial Officer The Brink’s Company 1801 Bayberry Court Richmond VA 23226
Re: The Brink’s Company Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 24, 2017 File No. 001 -09148
Dear Mr. Domanico :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of 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 your response to these comments, we may have additional comments.
Non-GAAP Reco nciled to GAAP , page 37
1. Please revise this presentation to include reconciling items within the reconciliations rather than cross -referencing to other tables within your filing.
Note 1 - Summary of Significant Accounting Policies
Principles of Consolida tion, page 69
2. On page 28, you disclose management’s inability to allocate, generate, or redeploy resources in-country or globally with respect to your Venezuela operations. In addition, you cite other factors related to Venezuela including:
Continued in ability to repatriate cash to redeploy to other operations or dividend to shareholders; Highly inflationary environment;
Ronald J. Domanico The Brink’s Company August 4, 2017 Page 2
Fixed exchange rate policy; Continued currency devaluations; and Difficulty raising prices and controlling costs.
Please tell us what consideration you gave to accounting for your Venezuelan operations by method other than consolidation. Refer to ASC 810 -10-15-10(a)(1)(iii) and 830 -20-30-2.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Patrick Kuhn at (202) 551 -3308 or me at (202) 551 -3380 if you have questions .
Sincerely,
/s/ Lyn Shenk
Show Raw Text
Mail Stop 3561 August 4, 2017 Ronald J. Domanico Executive Vice President and Chief Financial Officer The Brink’s Company 1801 Bayberry Court Richmond VA 23226 Re: The Brink’s Company Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 24, 2017 File No. 001 -09148 Dear Mr. Domanico : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of 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 your response to these comments, we may have additional comments. Non-GAAP Reco nciled to GAAP , page 37 1. Please revise this presentation to include reconciling items within the reconciliations rather than cross -referencing to other tables within your filing. Note 1 - Summary of Significant Accounting Policies Principles of Consolida tion, page 69 2. On page 28, you disclose management’s inability to allocate, generate, or redeploy resources in-country or globally with respect to your Venezuela operations. In addition, you cite other factors related to Venezuela including: Continued in ability to repatriate cash to redeploy to other operations or dividend to shareholders; Highly inflationary environment; Ronald J. Domanico The Brink’s Company August 4, 2017 Page 2 Fixed exchange rate policy; Continued currency devaluations; and Difficulty raising prices and controlling costs. Please tell us what consideration you gave to accounting for your Venezuelan operations by method other than consolidation. Refer to ASC 810 -10-15-10(a)(1)(iii) and 830 -20-30-2. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Patrick Kuhn at (202) 551 -3308 or me at (202) 551 -3380 if you have questions . Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief Office of Transportation and Leisure