SEC Comment Letter for ROLLINS INC (ROL) (CIK 0000084839) (ROL) — May 4, 2018
ROLLINS INC (ROL) (CIK 0000084839)
Date: May 4, 2018 · CIK: 0000084839 · Accession: 0000000000-18-013996
AI Filing Summary & Sentiment
File numbers found in text: 001-04422
Letter
Mail Stop 3233 May 4, 2018 Via E -mail Mr. Paul E. Northen Chief Financial Officer Rollins, Inc. 2170 Piedmont Road, N.E. Atlanta, GA 20324
Re: Rollins, Inc. Form 10 -K for the fiscal year ended December 31, 201 7 Filed on February 2 6, 201 8 File No. 001-04422
Dear Mr. Northen :
We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to the comment 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 comment appl ies to your facts and circumstances, p lease tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Note 14. Employee Benefit Plans
Fair Value Measurements, page 53
1. We note your disclosure of the valuation approach and inputs used to value the Level 2 and 3 assets of your defined benefit pension plan. Please expand your disclosure in future filings to include a description of the valuation techniques used in accordance with ASC 820 -10-50-2bbb.
We remind you that the compa ny 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.
Mr. Paul E. Northen Rollins , Inc. May 4, 201 8 Page 2
You may contact Becky Chow, Staff Accountant, at (202) 551 -6524 or me at (202) 551- 3429 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Kristi Marrone
Show Raw Text
Mail Stop 3233
May 4, 2018
Via E -mail
Mr. Paul E. Northen
Chief Financial Officer
Rollins, Inc.
2170 Piedmont Road, N.E.
Atlanta, GA 20324
Re: Rollins, Inc.
Form 10 -K for the fiscal year ended December 31, 201 7
Filed on February 2 6, 201 8
File No. 001-04422
Dear Mr. Northen :
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to the comment 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
comment appl ies to your facts and circumstances, p lease tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Note 14. Employee Benefit Plans
Fair Value Measurements, page 53
1. We note your disclosure of the valuation approach and inputs used to value the Level 2
and 3 assets of your defined benefit pension plan. Please expand your disclosure in
future filings to include a description of the valuation techniques used in accordance with
ASC 820 -10-50-2bbb.
We remind you that the compa ny 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.
Mr. Paul E. Northen
Rollins , Inc.
May 4, 201 8
Page 2
You may contact Becky Chow, Staff Accountant, at (202) 551 -6524 or me at (202) 551-
3429 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Kristi Marrone
Kristi Marrone
Staff Accountant
Office of Real Estate and
Commodities