SEC Comment Letter for Stagwell Inc (STGW) (CIK 0000876883) (STGW) — Oct 4, 2017
Stagwell Inc (STGW) (CIK 0000876883)
Date: Oct. 4, 2017 · CIK: 0000876883 · Accession: 0000000000-17-035342
AI Filing Summary & Sentiment
File numbers found in text: 001-13718
Letter
Mail Stop 3720 October 4 , 201 7 Scott L. Kauffman Chairman and Chief Executive Officer MDC Partners, Inc. 745 Fifth Avenue New York, New York 10151
Re: MDC Partners, Inc. Form 10-K for Fiscal Year December 31, 2016 as amended Response Dated August 31, 2017 File No. 001-13718
Dear Mr. Kaufmann :
We have reviewed your August 31, 2017 response and have the following c omment. In our comment, we ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not beli eve our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Item 9A. Controls and Procedures, page 104
1. We note in you r response that you determined there was a control deficiency in your internal control over financial reporting; however, the deficiency did not rise to the level of a material weakness. A control deficiency constitutes a material weakness if there is a reasonable possibility that a material misstatement of the financial statements would not be prevented or detected in a timely manner. Based on your determination that the disclosure misstatements in your prior SEC filings were material and a result of a c ontrol deficiency, we are unable to agree with your conclusion that the related deficiency is not a material weakness. Please explain how you will address and disclose the ineffectiveness of internal control over financial reporting and disclosure contro ls and procedures for the periods the material weakness existed.
Scott L. Kauffman MDC Partners, Inc. October 4 , 2017 Page 2
You may contact Kathryn Jacobson, Senior Staff Accountant , at (202) 551 -3365, or Robert S. Littlepage, Accountant Branch Chief, at (202) 551 -3361 if you have any questions regarding comments on the financial statements and related matters. Please contact Gregory Dundas, Attorney -Advisor, at (202) 551 -3436 or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage, for
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Mail Stop 3720 October 4 , 201 7 Scott L. Kauffman Chairman and Chief Executive Officer MDC Partners, Inc. 745 Fifth Avenue New York, New York 10151 Re: MDC Partners, Inc. Form 10-K for Fiscal Year December 31, 2016 as amended Response Dated August 31, 2017 File No. 001-13718 Dear Mr. Kaufmann : We have reviewed your August 31, 2017 response and have the following c omment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not beli eve our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Item 9A. Controls and Procedures, page 104 1. We note in you r response that you determined there was a control deficiency in your internal control over financial reporting; however, the deficiency did not rise to the level of a material weakness. A control deficiency constitutes a material weakness if there is a reasonable possibility that a material misstatement of the financial statements would not be prevented or detected in a timely manner. Based on your determination that the disclosure misstatements in your prior SEC filings were material and a result of a c ontrol deficiency, we are unable to agree with your conclusion that the related deficiency is not a material weakness. Please explain how you will address and disclose the ineffectiveness of internal control over financial reporting and disclosure contro ls and procedures for the periods the material weakness existed. Scott L. Kauffman MDC Partners, Inc. October 4 , 2017 Page 2 You may contact Kathryn Jacobson, Senior Staff Accountant , at (202) 551 -3365, or Robert S. Littlepage, Accountant Branch Chief, at (202) 551 -3361 if you have any questions regarding comments on the financial statements and related matters. Please contact Gregory Dundas, Attorney -Advisor, at (202) 551 -3436 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage, for Larry Spirgel Assistant Director AD Office 11 - Telecommunications