SEC Comment Letter for BRINKS CO (BCO) (CIK 0000078890) (BCO) — Apr 19, 2018
BRINKS CO (BCO) (CIK 0000078890)
Date: April 19, 2018 · CIK: 0000078890 · Accession: 0000000000-18-011980
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-09148
Letter
April 19, 2018 Ronald Domanico 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 the Fiscal Year Ended December 31, 2017 Filed March 1, 2018 Form 8-K Furnished February 7, 2018 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 business days by providing the requested information or advise 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. Form 10-K for Fiscal Year Ended December 31, 2017 Management's Discussion and Analysis of Financial Condition and Results of Operations Operations, page 21 1.We note segment operating profit as a percent of segment revenue varies materially between each segment for each period presented. In particular, the ratio for the North America segment is significantly lower than the ratio of the other two segments in each period. Please disclose the material factors that cause variances in the trend of this ratio between the segments and that cause the North America segment ratio to be lower. Refer to Item 303(a)(3)(iii) of Regulation S-K for guidance.
FirstName LastNameRonald Domanico Comapany NameThe Brink's Company June 16, 2017 Page 2 FirstName LastName Ronald Domanico The Brink's Company April 19, 2018 Page 2 Non-GAAP Results Reconciled to GAAP Non-GAAP reconciled to GAAP, page 36 2.Please present with equal or greater prominence the comparable GAAP margin to the non- GAAP margin presented. Refer to Item 10(e)(1)(i)(A) of Regulation S-K for guidance. Form 8-K Furnished February 7, 2018 Exhibit 99.1 Non-GAAP Results Reconciled to GAAP Adjusted EBITDA, page 13 3.You presently reconcile "adjusted EBITDA" to "Income from continuing operations - Non-GAAP." Please reconcile "adjusted EBITDA" to the most directly comparable GAAP measure. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Questions 103.01 and .02 of staff's Compliance and Disclosure Interpretation "Non-GAAP Financial Measures" for guidance. In closing, 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 Theresa Brillant at 202-551-3307 or Doug Jones at 202-551-3309 with any questions. Division of Corporation Finance Office of Transportation and Leisure
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April 19, 2018
Ronald Domanico
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 the Fiscal Year Ended December 31, 2017
Filed March 1, 2018
Form 8-K
Furnished February 7, 2018
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 business days by providing the requested
information or advise 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.
Form 10-K for Fiscal Year Ended December 31, 2017
Management's Discussion and Analysis of Financial Condition and Results of Operations
Operations, page 21
1.We note segment operating profit as a percent of segment revenue varies materially
between each segment for each period presented. In particular, the ratio for the North
America segment is significantly lower than the ratio of the other two segments in each
period. Please disclose the material factors that cause variances in the trend of this ratio
between the segments and that cause the North America segment ratio to be lower. Refer
to Item 303(a)(3)(iii) of Regulation S-K for guidance.
FirstName LastNameRonald Domanico
Comapany NameThe Brink's Company
June 16, 2017 Page 2
FirstName LastName
Ronald Domanico
The Brink's Company
April 19, 2018
Page 2
Non-GAAP Results Reconciled to GAAP
Non-GAAP reconciled to GAAP, page 36
2.Please present with equal or greater prominence the comparable GAAP margin to the non-
GAAP margin presented. Refer to Item 10(e)(1)(i)(A) of Regulation S-K for guidance.
Form 8-K Furnished February 7, 2018
Exhibit 99.1
Non-GAAP Results Reconciled to GAAP
Adjusted EBITDA, page 13
3.You presently reconcile "adjusted EBITDA" to "Income from continuing operations -
Non-GAAP." Please reconcile "adjusted EBITDA" to the most directly comparable
GAAP measure. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Questions 103.01
and .02 of staff's Compliance and Disclosure Interpretation "Non-GAAP Financial
Measures" for guidance.
In closing, 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 Theresa Brillant at 202-551-3307 or Doug Jones at 202-551-3309 with
any questions.
Division of Corporation Finance
Office of Transportation and Leisure