SEC Comment Letter for TEAM INC (TISI) (CIK 0000318833) (TISI) — Aug 1, 2017
TEAM INC (TISI) (CIK 0000318833)
Date: Aug. 1, 2017 · CIK: 0000318833 · Accession: 0000000000-17-027034
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File numbers found in text: 001-08604
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Mail Stop 3720 August 1, 2017 Ted W. Owen Chief Executive Officer Team, Inc. 13131 Dairy Ashford, Suite 600 Sugar Land, TX 77478 Re: Team, Inc. Form 10-K for Fiscal Year Ended December 31, 2016 Filed March 16, 2017 Form 8 -K filed May 10, 2017 File No. 001-08604 Dear Mr. Owen : We have limited our review of your filing to the financial statements and related disclosures and have the following comment . Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After review ing your response to this comment , we may have additional comments. Form 8 -K filed May 10, 2017 In future filings, please remove the description “non -routine” from any non -GAAP adjustment that has occurred in the prior two years or is reason ably likely to recur within the next two years. Please r efer to Question 102.03 of the updated Non -GAAP Compliance and Disclosure Interpretations issued on May 17, 2016. 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. Ted W. Owen Team, Inc. August 1, 2017 Page 2 You may contact Jamie Kessel at (202) 551 -3727 or Terry French at (202) 551-3828 with any questions. Sincerely, /s/ Terry French for Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications