SEC Comment Letter for BRINKS CO (BCO) (CIK 0000078890) (BCO) — Aug 25, 2017
BRINKS CO (BCO) (CIK 0000078890)
Date: Aug. 25, 2017 · CIK: 0000078890 · Accession: 0000000000-17-030105
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Mail Stop 3561 August 24 , 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 Response Dated August 14, 2017 Dear Mr. Domanico : We have reviewed your August 14, 2017 response to our comment letter and have the following comment . Our comment ask s 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 possi ble when you will respond. If you do not believe our comment applies to your facts and circumstances , please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our re ferences to prior comments are to comments in our August 4 , 2017 letter. Note 1: Summary of Significan t Accounting Principles Principles of Consolidation , page 69 1. We note your response to our prior comment two. You state that you do not bel ieve that the Venezuelan government has enacted other government sponsored regulations that effect your ability to control your Venezuelan operations. Further, you state that to the extent you have needed resources, you have been able to obtain them witho ut monetary or operational restrictions. However, this appears contradictory to the disclosures made in your filing, which we referenced in our prior comment two. Specifically, you disclosed the following in your filing: Ronald J. Domanico The Brink’s Company August 24 , 2017 Page 2 Management’s inability to alloca te, generate, or redeploy resources in -country or globally with respect to your Venezuela operations; Continued inability to repatriate cash to redeploy to other operations or dividend to shareholders; Highly inflationary environment; Fixed exchange rat e policy; Continued currency devaluations; and Difficulty raising prices and controlling costs. Please specifically address each of the disclosures we cited in our prior comment. You may contact Patrick Kuhn at (202) 551 -3308 or me at (202) 551 -3380 with any questions . Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief Office of Transportation and Leisure