SEC Comment Letter for ABM INDUSTRIES (ABM) — Oct 13, 2010
ABM INDUSTRIES INC /DE/ (ABM) (CIK 0000771497)
Date: Oct. 13, 2010 · CIK: 0000771497 · Accession: 0000000000-10-060125
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08929
Referenced dates: August 19, 2010, September 15, 2010
Letter
October 13, 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 Definitive Proxy Statement on Schedule 14A Filed February 1, 2010 File No. 001-08929
Dear Mr. James Lusk:
We have reviewed your letter dated September 15, 2010 in connection with the above- referenced filings 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 this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they re fer to our letter dated August 19, 2010. Form 10-K for the year ended October 31, 2009
Item 9A – Controls a nd Procedures, page 69
1. We note your response to prior comment one a nd your discussion of disclosure controls and procedures on page 69. You disclose th at “no evaluation of controls can provide absolute assurance that all control issues , if any, within the Company have been detected.” Since your disclosure indicates th at your disclosure c ontrols and procedures were designed to provide reason able assurance that the controls and procedures will meet their objectives, you should state, if true, th at your disclosure cont rols and procedures
James Lusk ABM Industries Incorporated October 13, 2010 [Page 2] were effective at the reasonable assurance level. Please confirm that management’s conclusions regarding the effec tiveness of your disclosure c ontrols and procedures were made at the reasonable assurance level and update your disclosure in future filings accordingly.
You may contact Jaime John, at (202) 551-3446 , Jessica Barberich at (202) 551-3782 or me at (202) 551-3413 if you have questions regard ing comments on the financial statements and related matters. Please cont act Sonia Barros at (202) 551-3655 or Phil Rothenberg at (202) 551- 3466 with any questions.
S i n c e r e l y , Cicely LaMothe Accounting Branch Chief
Show Raw Text
October 13, 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 Definitive Proxy Statement on Schedule 14A Filed February 1, 2010 File No. 001-08929
Dear Mr. James Lusk:
We have reviewed your letter dated September 15, 2010 in connection with the above-
referenced filings 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have addi tional comments. Unless otherwise noted, where
prior comments are referred to they re fer to our letter dated August 19, 2010.
Form 10-K for the year ended October 31, 2009
Item 9A – Controls a nd Procedures, page 69
1. We note your response to prior comment one a nd your discussion of disclosure controls
and procedures on page 69. You disclose th at “no evaluation of controls can provide
absolute assurance that all control issues , if any, within the Company have been
detected.” Since your disclosure indicates th at your disclosure c ontrols and procedures
were designed to provide reason able assurance that the controls and procedures will meet
their objectives, you should state, if true, th at your disclosure cont rols and procedures
James Lusk ABM Industries Incorporated October 13, 2010 [Page 2]
were effective at the reasonable assurance level. Please confirm that management’s conclusions regarding the effec tiveness of your disclosure c ontrols and procedures were
made at the reasonable assurance level and update your disclosure in future filings
accordingly.
You may contact Jaime John, at (202) 551-3446 , Jessica Barberich at (202) 551-3782 or
me at (202) 551-3413 if you have questions regard ing comments on the financial statements and
related matters. Please cont act Sonia Barros at (202) 551-3655 or Phil Rothenberg at (202) 551-
3466 with any questions.
S i n c e r e l y ,
Cicely LaMothe Accounting Branch Chief