SEC Comment Letter for SIGNET JEWELERS LTD (SIG) (CIK 0000832988) (SIG) — Oct 8, 2008
SIGNET JEWELERS LTD (SIG) (CIK 0000832988)
Date: Oct. 8, 2008 · CIK: 0000832988 · Accession: 0000000000-08-050661
AI Filing Summary & Sentiment
File numbers found in text: 001-32349
Referenced dates: August 25, 2008
Letter
Mail Stop 3561
October 3, 2008 Mark Jenkins Group Company Secretary Signet Group plc 15 Golden Square London W1F 9JG England Re: Signet Group plc Form 20-F for Fiscal Year Ended February 2, 2008 Filed May 9, 2008 File No. 001-32349 Dear Mr. Jenkins: We have reviewed your filing and have the following comments. You should comply with the comments in all future filings, as appl icable. Please confirm in writing that you will do so, and also explain to us in sufficient detail for an understa nding of the disclosure how you intend to comply by providing us with your prop osed revisions. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessa ry in your explanation. After re viewing this information, we may raise additional comments. Form 20-F for Fiscal Year Ended February 2, 2008
Exhibit 15.3
Note 1. Principal accounting policies, page 86 (a) Basis of preparation, page 86 1. We have reviewed your response to commen t two in our letter dated August 25, 2008. Please tell us in further detail why you conc luded the timing of the change in functional currency was appropriate as opposed to some ear lier date. In this regard, please provide us with a timeline that demonstrates the pe riod over which the majority of your business became denominated in US dollars. Specifically tell us the percentage of your sales, operating profit, net assets and borrowings denom inated in US dollars for each of the last 3 years. Additionally, it appears that pa ragraph 9(a)(i) of IAS 21 was a determining factor in your decision to cha nge the functional currency. Pl ease tell us the extent to which paragraphs 9(a)(ii)-11 also impacted your decision. Furthermore, tell us the economic significance of the re-denomination of your share capital in February 2007 and why this contributed to your decision to ch ange the functional curr ency. Finally, provide
Mark Jenkins Signet Group plc October 3, 2008 Page 2 us with a summary of the per centage change in sales and net income had the functional currency remained the pound for fiscal 2008. Provide us with a similar analysis had the functional currency been the dollar for fiscal year 2007. We may have further comment.
*****
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your respon ses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Sarah Goldberg, Assistant Chief Accountant, at (202) 551-3340 or Jim Allegretto, Senior Assistant Chief Accountant, at (202) 551-3720 with an y questions regarding the comments on financial statements and related matters. You may contact Blair Petrillo, Staff Attorney, at (202) 551-3550 or me at (202) 551-3720 with any other questions.
Sincerely,
H. Christopher Owings Assistant Director
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Mail Stop 3561
October 3, 2008 Mark Jenkins Group Company Secretary Signet Group plc 15 Golden Square London W1F 9JG England
Re: Signet Group plc
Form 20-F for Fiscal Year Ended February 2, 2008
Filed May 9, 2008 File No. 001-32349
Dear Mr. Jenkins:
We have reviewed your filing and have the following comments. You should comply with the comments in all future filings, as appl icable. Please confirm in writing that you will do
so, and also explain to us in sufficient detail for an understa nding of the disclosure how you
intend to comply by providing us with your prop osed revisions. If you disagree, we will
consider your explanation as to why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry in your explanation. After re viewing this information, we may
raise additional comments.
Form 20-F for Fiscal Year Ended February 2, 2008
Exhibit 15.3
Note 1. Principal accounting policies, page 86
(a) Basis of preparation, page 86
1. We have reviewed your response to commen t two in our letter dated August 25, 2008.
Please tell us in further detail why you conc luded the timing of the change in functional
currency was appropriate as opposed to some ear lier date. In this regard, please provide
us with a timeline that demonstrates the pe riod over which the majority of your business
became denominated in US dollars. Specifically tell us the percentage of your sales,
operating profit, net assets and borrowings denom inated in US dollars for each of the last
3 years. Additionally, it appears that pa ragraph 9(a)(i) of IAS 21 was a determining
factor in your decision to cha nge the functional currency. Pl ease tell us the extent to
which paragraphs 9(a)(ii)-11 also impacted your decision. Furthermore, tell us the
economic significance of the re-denomination of your share capital in February 2007 and why this contributed to your decision to ch ange the functional curr ency. Finally, provide
Mark Jenkins
Signet Group plc October 3, 2008 Page 2
us with a summary of the per centage change in sales and net income had the functional
currency remained the pound for fiscal 2008. Provide us with a similar analysis had the functional currency been the dollar for fiscal year 2007. We may have further comment.
*****
Please respond to these comments within 10 business days or tell us when you will
provide us with a response. Please furnish a letter that keys your respon ses to our comments and
provides any requested information. Detailed letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing your responses to our comments.
You may contact Sarah Goldberg, Assistant Chief Accountant, at (202) 551-3340 or Jim
Allegretto, Senior Assistant Chief Accountant, at (202) 551-3720 with an y questions regarding
the comments on financial statements and related matters. You may contact Blair Petrillo, Staff
Attorney, at (202) 551-3550 or me at (202) 551-3720 with any other questions.
Sincerely,
H. Christopher Owings Assistant Director