SEC Comment Letter for AECOM (ACM) — Mar 21, 2011
AECOM
Date: March 21, 2011 · CIK: 0000868857 · Accession: 0000000000-11-017181
AI Filing Summary & Sentiment
Referenced dates: December 29, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631
DIVISION OF CORPORATION FINANCE
February 9, 2011
via U.S. mail and facsimile
John M. Dionisio, Chief Executive Officer AECOM Technology Corporation 555 South Flower Street, Suite 3700 Los Angeles, California 90071 RE: AECOM Technology Corporation Form 10-K for the Fiscal Ye ar Ended September 30, 2010 Filed November 22, 2010 File No. 0-52423 Dear Mr. Dionisio:
We have reviewed your amended reports filed February 4, 2011 and have the following additional comments. If you disagree , we will consider your explanation as to why our comment is inapplicable. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments.
Quarterly Report on Form 10-Q/A for the Period Ended March 31, 2010
Item 6. Exhibits
1. We note that you have amended your quarterly report on Form 10-Q for the quarterly period ended March 31, 2010, to provide an omitted exhibit, consistent with your undertaking in your response to comment 17 in our comment letter dated December 29, 2010. Exhibit 10.12 to the amended quarterly report is incorpor ated by reference from Exhibit 99.3 to the current report on Form 8-K you filed on Marc h 31, 2010. We note, however, that there is no Exhibit 99.3 to aforementione d current report; there is only an Exhibit 99. Please revise your exhib it index to correctly identify the incorporated exhibit.
2. Please amend your quarterly report on Form 10-Q to provide the complete certifications required by Item 601(b)( 31) and Item 601(b)(32) of Regulation S-K. The abbreviated certifications you filed are not sufficient. This
Mr. Dionisio AECOM Technology Corporation February 9, 2011 Page 2 comment also applies to your Form 10-Q/A for the period ended June 30, 2010. Quarterly Report on Form 10-Q/A for the Period Ended June 30, 2010
Item 6. Exhibits
3. Exhibits 10.14 and 10.15 appear to incorpor ate the same exhibit by reference. Please amend your Form 10-Q to include the Management Fee Subordination Agreement as an exhibit. You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her absence Al Pavot at (202) 551-3738, or th e undersigned Accounting Branch Chief at (202) 551-3355 if you have questions regard ing comments on the financial statements and related matters. Please contact Jessica Ka ne at (202) 551-3235 w ith any legal related questions. Sincerely,
T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
February 9, 2011
via U.S. mail and facsimile
John M. Dionisio, Chief Executive Officer AECOM Technology Corporation 555 South Flower Street, Suite 3700 Los Angeles, California 90071
RE: AECOM Technology Corporation
Form 10-K for the Fiscal Ye ar Ended September 30, 2010
Filed November 22, 2010
File No. 0-52423
Dear Mr. Dionisio:
We have reviewed your amended reports filed February 4, 2011 and have the
following additional comments. If you disagree , we will consider your explanation as to
why our comment is inapplicable.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
Quarterly Report on Form 10-Q/A for the Period Ended March 31, 2010
Item 6. Exhibits
1. We note that you have amended your quarterly report on Form 10-Q for the
quarterly period ended March 31, 2010, to provide an omitted exhibit,
consistent with your undertaking in your response to comment 17 in our comment letter dated December 29, 2010. Exhibit 10.12 to the amended quarterly report is incorpor ated by reference from Exhibit 99.3 to the current
report on Form 8-K you filed on Marc h 31, 2010. We note, however, that
there is no Exhibit 99.3 to aforementione d current report; there is only an
Exhibit 99. Please revise your exhib it index to correctly identify the
incorporated exhibit.
2. Please amend your quarterly report on Form 10-Q to provide the complete
certifications required by Item 601(b)( 31) and Item 601(b)(32) of Regulation
S-K. The abbreviated certifications you filed are not sufficient. This
Mr. Dionisio
AECOM Technology Corporation February 9, 2011 Page 2
comment also applies to your Form 10-Q/A for the period ended June 30,
2010.
Quarterly Report on Form 10-Q/A for the Period Ended June 30, 2010
Item 6. Exhibits
3. Exhibits 10.14 and 10.15 appear to incorpor ate the same exhibit by reference.
Please amend your Form 10-Q to include the Management Fee Subordination Agreement as an exhibit.
You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her
absence Al Pavot at (202) 551-3738, or th e undersigned Accounting Branch Chief at
(202) 551-3355 if you have questions regard ing comments on the financial statements
and related matters. Please contact Jessica Ka ne at (202) 551-3235 w ith any legal related
questions.
Sincerely,
T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f