SEC Company Response from AECOM (ACM) — Mar 23, 2012
AECOM
Date: March 23, 2012 · CIK: 0000868857 · Accession: 0001104659-12-020726
AI Filing Summary & Sentiment
File numbers found in text: 000-52423
Referenced dates: February 6, 2012
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Re: AECOM Technology Corporation Form 10-K for the Fiscal Year Ended September 30, 2011 Filed November 21, 2011 File No. 000-52423
Dear Mr. O’Brien:
This letter is in further response to the comment letter, dated January 23, 2012, of the Staff of the Division of Corporation Finance (the “Staff”) regarding the above-referenced filing for AECOM Technology Corporation (“AECOM” or the “Company”). To assist your review, we have retyped the text of the Staff’s comments in italics below.
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 related to your allowance for doubtful accounts; however you report from your independent auditor 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.
RESPONSE
As stated in the Company’s letter dated February 6, 2012, the Company will amend its filing to include an opinion for Schedule II related to allowance for doubtful accounts from the Company’s independent auditor, Ernst & Young LLP. The Company confirms that the amended filing will contain the report of the independent auditors covering Schedule II, consent of independent registered public accounting firm, certifications of the Company’s Chief Executive Officer and Chief Financial Officer pursuant to Section 302 of the Sarbanes Oxley Act of 2002, and certification of the Company’s Chief Executive Officer and Chief Financial Officer pursuant to Section 906 of the Sarbanes Oxley Act of 2002.
Please contact the undersigned at (212) 973-3045 with any questions or comments you may have regarding this letter.
Very truly yours,
/s/ Nancy J. Laben
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CORRESP 1 filename1.htm AECOM 213.593.8000 tel 555 S. Flower Street 213.593.8730 fax Suite 3700 Los Angeles, CA 90071 www.aecom.com March 23, 2012 VIA EDGAR Terrence O’Brien Accounting Branch Chief Securities and Exchange Commission Division of Corporation Finance 1 Station Place, N.E., Stop 7010 Washington, D.C. 20549 Re: AECOM Technology Corporation Form 10-K for the Fiscal Year Ended September 30, 2011 Filed November 21, 2011 File No. 000-52423 Dear Mr. O’Brien: This letter is in further response to the comment letter, dated January 23, 2012, of the Staff of the Division of Corporation Finance (the “Staff”) regarding the above-referenced filing for AECOM Technology Corporation (“AECOM” or the “Company”). To assist your review, we have retyped the text of the Staff’s comments in italics below. 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 related to your allowance for doubtful accounts; however you report from your independent auditor 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. RESPONSE As stated in the Company’s letter dated February 6, 2012, the Company will amend its filing to include an opinion for Schedule II related to allowance for doubtful accounts from the Company’s independent auditor, Ernst & Young LLP. The Company confirms that the amended filing will contain the report of the independent auditors covering Schedule II, consent of independent registered public accounting firm, certifications of the Company’s Chief Executive Officer and Chief Financial Officer pursuant to Section 302 of the Sarbanes Oxley Act of 2002, and certification of the Company’s Chief Executive Officer and Chief Financial Officer pursuant to Section 906 of the Sarbanes Oxley Act of 2002. Please contact the undersigned at (212) 973-3045 with any questions or comments you may have regarding this letter. Very truly yours, /s/ Nancy J. Laben Nancy J. Laben Senior Vice President and General Counsel cc: John M. Dionisio, Chairman and Chief Executive Officer, AECOM Technology Corporation Stephen M. Kadenacy, Executive Vice President, Chief Financial Officer, AECOM Technology Corporation 2