CORRESP Filing
ABM INDUSTRIES INC /DE/
Date: May 1, 2025 · CIK: 0000771497 · Accession: 0000771497-25-000011
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 25, 2025
Letter
Document One Liberty Plaza, 7 th Floor New York, N.Y. 10006 Office: (212) 297-0200 Fax: (212) 297-0375 May 1, 2025 VIA EDGAR United States Securities and Exchange Commission Division of Corporate Finance Office of Trade & Services 100 F Street, NE Washington, D.C. 20549 Attention: Ta Tanisha Meadows and Joel Parker Re: ABM Industries Incorporated Form 10-K for Fiscal Year Ended October 31, 2024 Form 8-K Filed December 18, 2024 File No. 1-08929 Ladies and Gentlemen: On behalf of ABM Industries Incorporated (referred to as “ABM,” “we,” “our,” or the “Company”), we acknowledge receipt of the Staff’s response dated April 25, 2025, regarding our non-GAAP reconciliation presented in the Form 8-K filed on December 18, 2024, specifically related to the adjustment for “Prior year self-insurance adjustment.” We respectfully confirm that we will revise our presentation in future filings and earnings materials to exclude the Prior year self-insurance adjustment from our calculation of non-GAAP financial measures, consistent with the Staff’s guidance and in accordance with Item 10(e) of Regulation S-K or Regulation G. If you have any questions or need further information, please email me at earl.ellis@abm.com. Very truly yours, /s/ Earl R. Ellis Executive Vice President and Chief Financial Officer
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CORRESP 1 filename1.htm Document One Liberty Plaza, 7 th Floor New York, N.Y. 10006 Office: (212) 297-0200 Fax: (212) 297-0375 May 1, 2025 VIA EDGAR United States Securities and Exchange Commission Division of Corporate Finance Office of Trade & Services 100 F Street, NE Washington, D.C. 20549 Attention: Ta Tanisha Meadows and Joel Parker Re: ABM Industries Incorporated Form 10-K for Fiscal Year Ended October 31, 2024 Form 8-K Filed December 18, 2024 File No. 1-08929 Ladies and Gentlemen: On behalf of ABM Industries Incorporated (referred to as “ABM,” “we,” “our,” or the “Company”), we acknowledge receipt of the Staff’s response dated April 25, 2025, regarding our non-GAAP reconciliation presented in the Form 8-K filed on December 18, 2024, specifically related to the adjustment for “Prior year self-insurance adjustment.” We respectfully confirm that we will revise our presentation in future filings and earnings materials to exclude the Prior year self-insurance adjustment from our calculation of non-GAAP financial measures, consistent with the Staff’s guidance and in accordance with Item 10(e) of Regulation S-K or Regulation G. If you have any questions or need further information, please email me at earl.ellis@abm.com. Very truly yours, /s/ Earl R. Ellis Executive Vice President and Chief Financial Officer