SecProbe.io

Mail Stop 3233
April 1 , 2016

Via E -mail
Mr. D. Anthony Scaglione
Chief  Financial Officer
ABM Industries Incorporated
551 Fifth Avenue, Suite 300
New York, N Y 10176

Re: ABM Industries Incorporated
Form 10 -K for the fiscal year ended October 31, 2015
Filed December 17, 2015
             File No. 001-08929

Dear Mr. Scaglione :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  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
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Item 8.  Financial Statements and Supplementary Data

Report of Independent Registered Public Accounting Firm, page 54

1. We note that the report  of your independent registered public accounting firm state s that
the audits were conducted “in accordance with the auditing standards of the Public
Company Accounti ng Oversight Board (United States). ”  Please have your auditor tell us
why the report refers to the “auditing standards” of the PCAOB instead of all standards of
the PCAOB.  If true, amend your Form 10 -K to include an audit  report  to state that the
audits were conducted in accordance with “the standards of the Public Company
Accounting Oversight Board (United States) .”  Refer to Auditing Standards No. 1.

Mr. D. Anthony Scaglione
ABM Industries Incorporated
April 1 , 2016
Page 2

 Note 12. Insurance , page 76

2. In future periodic filings, please disclose a roll forward of your insurance rese rves for
each year presented.   The roll forward should include the amount of incurred claims, any
changes in the provision for prior year events, and the amount of payments made.
Provide an example of your proposed disclosure.  To the extent you do not bel ieve this
disclosure is material ; tell us how you made that determination.   Refer to ASC 944 -40-
50-3.

3. We note in your disclosure on page 27 that $36 million of the $42 million increase  in
your insurance reserves re lates to year s prior to 2015.  We furth er note on page 76 that
your gener al liability reserve increase was due in  part to an increase in the number of
premises liability claims from earlier years reported to you subsequent to the 2014
actuarial evaluations .  Please provide additio nal details re garding the nature, amount and
timing associated with these additional claims to clarify why recognition occurred during
2015 and was not required in 2014 .

4. Additionally we note  that the adverse development related to your automobile liability
was primar ily attributable to three large multi -party claims that occurred in the 2013
policy year.   Please provide to us additional details regarding the nature, amount and
extent of new events that occurred during 2015 associated with these claims or additional
experience or information obtained since the last reporting date that led to the change in
estimate.  Also ensure that your response addresses the timing associated with these
events to clarify why recognition occurred during 2015 and was not required in 201 4.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the c ompany and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from  taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Mr. D. Anthony Scaglione
ABM Industries Incorporated
April 1 , 2016
Page 3

 You may contact Becky Chow, Sta ff Accountant,  at (202) 551 -6524  or the undersigned at
(202) 551 -3446  if you have any questions.

Sincerely,

 /s/ Jaime G. John

Jaime G. John
Branch Chief
Office of Real Estate and
Commodities