SEC Comment Letter for ABM INDUSTRIES (ABM) — Apr 14, 2017
ABM INDUSTRIES INC /DE/ (ABM) (CIK 0000771497)
Date: April 14, 2017 · CIK: 0000771497 · Accession: 0000000000-17-012950
AI Filing Summary & Sentiment
Letter
April 14, 2017 Via E -Mail Mr. D. Anthony Scaglione Executive Vice President and Chief Financial Officer ABM Industries Incorporated One Liberty Plaza, 7th Floor New York, NY 10006 Form 8 -K Filed December 14, 2016 File No. 001 -08929
Re: ABM Industries Incorporated Form 10 -K for the f iscal year ended Octo ber 31, 20 16 Filed December 21, 2016 File No. 00 1-08929
Dear M r. Scaglione:
We have reviewed your March 24, 2017 response to our comment letter 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 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 co mments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 1, 2017 letter .
Form 8 -K filed December 14, 2016
Exhibit 99.2
1. We note your response to comment 5 that in future presentations, when you present historical or projected non -GAAP measures, you will provide the most comparable GAAP measures, except to th e extent that, with respect to projected non -GAAP financial measures, you rely on the “unreasonable efforts” exception contained in Regulation G. Please confirm that to the extent that you rely on the referenced
Mr. D. Anthony Scaglione ABM Industries Incorporated April 14, 2017 Page 2
exception in future filings, you will disclo se that fact and identify the information that is unavailable and its probable significance in a location of equal or greater prominence.
You may contact Jorge L. Bonilla at (202) 551 -3414 or me at (202) 551 -3429 with any questions .
Sincerely,
/s/ Kristi Marrone
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Mail Stop 3233
April 14, 2017
Via E -Mail
Mr. D. Anthony Scaglione
Executive Vice President and Chief Financial Officer
ABM Industries Incorporated
One Liberty Plaza, 7th Floor
New York, NY 10006
Re: ABM Industries Incorporated
Form 10 -K for the f iscal year ended Octo ber 31, 20 16
Filed December 21, 2016
File No. 00 1-08929
Form 8 -K
Filed December 14, 2016
File No. 001 -08929
Dear M r. Scaglione:
We have reviewed your March 24, 2017 response to our comment letter 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 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 co mments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment , we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments
in our March 1, 2017 letter .
Form 8 -K filed December 14, 2016
Exhibit 99.2
1. We note your response to comment 5 that in future presentations, when you present
historical or projected non -GAAP measures, you will provide the most comparable
GAAP measures, except to th e extent that, with respect to projected non -GAAP
financial measures, you rely on the “unreasonable efforts” exception contained in
Regulation G. Please confirm that to the extent that you rely on the referenced
Mr. D. Anthony Scaglione
ABM Industries Incorporated
April 14, 2017
Page 2
exception in future filings, you will disclo se that fact and identify the information
that is unavailable and its probable significance in a location of equal or greater
prominence.
You may contact Jorge L. Bonilla at (202) 551 -3414 or me at (202) 551 -3429
with any questions .
Sincerely,
/s/ Kristi Marrone
Kristi Marrone
Staff Accountant
Office of Real Estate and
Commodities