UPLOAD Filing
ABM INDUSTRIES INC /DE/
Date: April 25, 2025 · CIK: 0000771497 · Accession: 0000000000-25-004395
AI Filing Summary & Sentiment
Reasoning
Letter
Re: ABM Industries Incorporated Form 8-K Filed December 18, 2024 Response dated March 28, 2025 File No. 1-08929 Dear Earl Ellis:
April 25, 2025
Earl Ellis Chief Financial Officer ABM Industries Incorporated One Liberty Plaza, 7th Floor New York, NY 10006
We have reviewed your March 28, 2025 response to our comment letter and have the following comment(s).
Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 6, 2025 letter.
Form 8-K Filed December 18, 2024 Exhibit 99.1 Reconciliations of Non-GAAP Financial Measures
1. We note your response to our prior comment. We believe that the "Prior year self- insurance adjustment" to arrive at the non-GAAP financial measures Adjusted Net Income and Adjusted EBITDA is inconsistent with the guidance in Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations because it removes a component of the reserve that is required by GAAP. Please revise your presentation to exclude this adjustment in your calculation of any non- GAAP financial measures presented in accordance with Item 10(e) of Regulation S-K or Regulation G. April 25, 2025 Page 2
Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Dean Chin, Chief Accounting Officer
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> April 25, 2025 Earl Ellis Chief Financial Officer ABM Industries Incorporated One Liberty Plaza, 7th Floor New York, NY 10006 Re: ABM Industries Incorporated Form 8-K Filed December 18, 2024 Response dated March 28, 2025 File No. 1-08929 Dear Earl Ellis: We have reviewed your March 28, 2025 response to our comment letter and have the following comment(s). Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 6, 2025 letter. Form 8-K Filed December 18, 2024 Exhibit 99.1 Reconciliations of Non-GAAP Financial Measures 1. We note your response to our prior comment. We believe that the "Prior year self- insurance adjustment" to arrive at the non-GAAP financial measures Adjusted Net Income and Adjusted EBITDA is inconsistent with the guidance in Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations because it removes a component of the reserve that is required by GAAP. Please revise your presentation to exclude this adjustment in your calculation of any non- GAAP financial measures presented in accordance with Item 10(e) of Regulation S-K or Regulation G. April 25, 2025 Page 2 Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Dean Chin, Chief Accounting Officer </TEXT> </DOCUMENT>