SEC Company Response from ROLLINS INC (ROL) (CIK 0000084839) (ROL) — May 16, 2018
ROLLINS INC (ROL) (CIK 0000084839)
Date: May 16, 2018 · CIK: 0000084839 · Accession: 0001654954-18-005536
AI Filing Summary & Sentiment
Referenced dates: May 4, 2018
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance RE: Rollins, Inc. File No. 1-04422 Form 10-K for the year ended December 31, 2017
Dear Ms. Marrone:
We are legal counsel to Rollins, Inc. (the “Company”). This letter provides the Company’s responses to the comments in your letter dated May 4, 2018 about the Company’s referenced filing. In an effort to facilitate the Staff’s review, we have repeated the comments prior to setting forth the Company’s response thereto.
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.
The Company will expand its disclosure in future filings to include a description of the valuation techniques used in accordance with ASC 820-10-50-2bbb.
Atlanta ● Washington D.C.
Ms. Kristi Marrone
May 16,
Page
Please direct any further comments or questions to me at (404) 873-8528.
Sincerely,
ARNALL
GOLDEN GREGORY LLP
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CORRESP 1 filename1.htm Blueprint Atlanta Office 171 17th Street NW, Suite 2100 Atlanta, GA 30363-1031 Direct phone: 404.873.8528 Direct fax: 404.873.8529 E-mail: stephen.fox@agg.com May 16, 2018 VIA EDGAR Ms. Kristi Marrone United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 RE: Rollins, Inc. File No. 1-04422 Form 10-K for the year ended December 31, 2017 Dear Ms. Marrone: We are legal counsel to Rollins, Inc. (the “Company”). This letter provides the Company’s responses to the comments in your letter dated May 4, 2018 about the Company’s referenced filing. In an effort to facilitate the Staff’s review, we have repeated the comments prior to setting forth the Company’s response thereto. 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. The Company will expand its disclosure in future filings to include a description of the valuation techniques used in accordance with ASC 820-10-50-2bbb. Atlanta ● Washington D.C. Ms. Kristi Marrone May 16, 2018 Page 2 Please direct any further comments or questions to me at (404) 873-8528. Sincerely, ARNALL GOLDEN GREGORY LLP /s/ Stephen D. Fox Stephen D. Fox cc: Mr. Paul Edward Northen Mr. Edwin Page