SEC Comment Letter for ABM INDUSTRIES (ABM) — Feb 23, 2010
ABM INDUSTRIES INC /DE/ (ABM) (CIK 0000771497)
Date: Feb. 23, 2010 · CIK: 0000771497 · Accession: 0000000000-10-010371
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08929
Letter
Mail Stop 3010 February 23, 2010 Mr. James Lusk Chief Financial Officer ABM Industries Incorporated 551 Fifth Avenue, Suite 300 New York, New York 10176
Re: ABM Industries Incorporated Form 10-K for the year ended October 31, 2008 Filed December 22, 2008 Form 10-K for the year ended October 31, 2009 Filed December 22, 2009 File No. 001-08929
Dear Mr. James Lusk: We have reviewed your response lette r dated January 15, 2010 and have the following additional comments. Where i ndicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Provide to us the information requested if indi cated and please be as detailed as necessary in your explanation. General
1. Please note that our review of your res ponses to certain outstanding comments is still in process as we await the addi tional information requested during our teleconference on February 17, 2010. Form 10-K for the year ended October 31, 2009
Financial Statements and Notes
Note 2 – Basis of Presentation and Su mmary of Significant Accounting Policies
Trade Accounts Receivable Allowances, page 46
2. Your response to comment one includes a discussion of a $3.8 million specific reserve and an $8.7 million reserve related to bad debts and sale allowances.
James Lusk ABM Industries Incorporated February 23, 2010 Page 2 Reconcile this characteri zation with your accounting policy disclosure and the amounts reported in your Schedule of Cons olidated Valuation Accounts on page 74. Additionally, we note that your Schedule of Consolidated Valuation Accounts reflects a significant increase in charges to costs and expenses in your sales allowance during 2009. We further note that your accounting policy states that the sales allowance estimate is based on an analysis of the historical rate of sales adjustments. Please describe the r easons for the increase in sales allowances during 2009 and your assessment for the adequacy of the reserve as of October 31, 2009. Note 11 – Commitments and Contingencies
Contingencies, page 61
3. We note that your response to comment seven contradicts you r disclosure which states that the claim was settled in the year ended October 31, 2008. Please advise. * * * * * As appropriate, please respond to these comm ents within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover le tters greatly facilitate our review. Please submit your cover letter on EDGAR. Please understand that we may ha ve additional comments after reviewing your responses to our comments. You may contact Jaime John, at (202) 551-3446 or me, at (202) 551-3782 if you have questions. S i n c e r e l y , Jessica Barberich Assistant Chief Accountant
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Mail Stop 3010 February 23, 2010 Mr. James Lusk Chief Financial Officer ABM Industries Incorporated 551 Fifth Avenue, Suite 300 New York, New York 10176 Re: ABM Industries Incorporated Form 10-K for the year ended October 31, 2008 Filed December 22, 2008 Form 10-K for the year ended October 31, 2009 Filed December 22, 2009 File No. 001-08929 Dear Mr. James Lusk: We have reviewed your response lette r dated January 15, 2010 and have the following additional comments. Where i ndicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Provide to us the information requested if indi cated and please be as detailed as necessary in your explanation. General 1. Please note that our review of your res ponses to certain outstanding comments is still in process as we await the addi tional information requested during our teleconference on February 17, 2010. Form 10-K for the year ended October 31, 2009 Financial Statements and Notes Note 2 – Basis of Presentation and Su mmary of Significant Accounting Policies Trade Accounts Receivable Allowances, page 46 2. Your response to comment one includes a discussion of a $3.8 million specific reserve and an $8.7 million reserve related to bad debts and sale allowances. James Lusk ABM Industries Incorporated February 23, 2010 Page 2 Reconcile this characteri zation with your accounting policy disclosure and the amounts reported in your Schedule of Cons olidated Valuation Accounts on page 74. Additionally, we note that your Schedule of Consolidated Valuation Accounts reflects a significant increase in charges to costs and expenses in your sales allowance during 2009. We further note that your accounting policy states that the sales allowance estimate is based on an analysis of the historical rate of sales adjustments. Please describe the r easons for the increase in sales allowances during 2009 and your assessment for the adequacy of the reserve as of October 31, 2009. Note 11 – Commitments and Contingencies Contingencies, page 61 3. We note that your response to comment seven contradicts you r disclosure which states that the claim was settled in the year ended October 31, 2008. Please advise. * * * * * As appropriate, please respond to these comm ents within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover le tters greatly facilitate our review. Please submit your cover letter on EDGAR. Please understand that we may ha ve additional comments after reviewing your responses to our comments. You may contact Jaime John, at (202) 551-3446 or me, at (202) 551-3782 if you have questions. S i n c e r e l y , Jessica Barberich Assistant Chief Accountant