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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

Financial Reporting Regulatory Compliance Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-08604

Date
August 1, 2017
Author
/s/ Terry French for
Form
UPLOAD
Company
TEAM INC (TISI) (CIK 0000318833)

Letter

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

Show Raw Text
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