SEC Comment Letter for ABM INDUSTRIES (ABM) — Apr 27, 2017
ABM INDUSTRIES INC /DE/ (ABM) (CIK 0000771497)
Date: April 27, 2017 · CIK: 0000771497 · Accession: 0000000000-17-014664
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3233 April 27, 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
Dear M r. Scaglione:
We have reviewed your April 17 , 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 comment appl ies 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 April 14 , 2017 letter.
Consolidated Statements of Comprehensive Income, page 52
1. We note the significant increase in foreign currency translation loss in 2016. With a view towards MD&A disclosure in future filings, please tell us the reason for the significant fluctuation and the expected impact in future years.
Mr. D. Anthony Scaglione ABM Industries Incorp orated April 27, 2017 Page 2
You may contact Jorge L. Bonilla at (202) 551 -3414 or me at (202) 551 -3429 with any questions .
Sincerely,
/s/ Kristi Marrone
Show Raw Text
Mail Stop 3233
April 27, 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
Dear M r. Scaglione:
We have reviewed your April 17 , 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 comment appl ies 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 April 14 , 2017 letter.
Consolidated Statements of Comprehensive Income, page 52
1. We note the significant increase in foreign currency translation loss in 2016. With a
view towards MD&A disclosure in future filings, please tell us the reason for the
significant fluctuation and the expected impact in future years.
Mr. D. Anthony Scaglione
ABM Industries Incorp orated
April 27, 2017
Page 2
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