SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for AECOM (ACM) — Jan 23, 2012

AECOM
Date: Jan. 23, 2012 · CIK: 0000868857 · Accession: 0000000000-12-003515

AI Filing Summary & Sentiment

File numbers found in text: 000-52423

Date
January 23, 2012
Author
Not clearly detected
Form
UPLOAD
Company
AECOM

Letter

RE: AECOM Technology Corporation Form 10-K for the Fiscal Ye ar Ended September 30, 2011 Filed November 21, 2011 File No. 000-52423 Dear Mr. Dionisio:

January 23, 2012

Via E-mail John M. Dionisio Chief Executive Officer AECOM Technology Corporation 555 South Flower Street, Suite 3700 Los Angeles, California 90071

We have reviewed your filing and have the following comment. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended September 30, 2011

Report of Independent Registered Public Accounting Firm, page 60

1. We note that you present a Schedule II rela ted to your allowance for doubtful accounts; however your report from your independent aud itor does not provide an opinion for such schedule. Please amend your filing accordingly. Refer to the Instructions for Rule 5-04 of Regulation S-X for guidance.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment, please provide a written statement from the company acknowledging that:

Mr. Dionisio AECOM Technology Corporation January 23, 2012 Page 2

 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States. You may contact Tracey McKoy, Staff Accountant, at (202) 551- 3772 or, in her absence, Al Pavot, Staff Accountant at, (202) 551- 3738 or, the undersigned Accounting Branch Chief at (202) 551-3355 if you have questions regardi ng comments on the financial statements and related matters. Sincerely, / s / T e r e n c e O ’ B r i e n 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

Show Raw Text
January 23, 2012

Via E-mail
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, 2011
  Filed November 21, 2011   File No. 000-52423
Dear Mr. Dionisio:

We have reviewed your filing and have the following comment.  Please respond to this
letter within ten business days by amending your  filing, by providing the requested information,
or by advising us when you will provide the requested response.  If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate,
please tell us why in your response.
 After reviewing the information you provide in  response to this comment, we may have
additional comments.
Form 10-K for the Fiscal Year Ended September 30, 2011

 Report of Independent Registered Public Accounting Firm, page 60

1. We note that you present a Schedule II rela ted to your allowance for doubtful accounts;
however your report from your independent aud itor does not provide an opinion for such
schedule.  Please amend your filing accordingly.  Refer to the Instructions for Rule 5-04
of Regulation S-X for guidance.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comment, please provide a written statement from the company
acknowledging that:

Mr. Dionisio
AECOM Technology Corporation January 23, 2012 Page 2

 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.
  You may contact Tracey McKoy, Staff Accountant, at (202) 551- 3772 or, in her absence, Al
Pavot, Staff Accountant at, (202)  551- 3738 or, the undersigned Accounting Branch Chief at
(202) 551-3355 if you have questions regardi ng comments on the financial statements and
related matters.
Sincerely,
         / s /  T e r e n c e  O ’ B r i e n           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