SEC Comment Letter for Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Feb 14, 2008
Invesco Ltd. (IVZ) (CIK 0000914208)
Date: Feb. 14, 2008 · CIK: 0000914208 · Accession: 0000000000-08-008356
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE February 14, 2008 Mr. Kevin M. Carome General Counsel Invesco Ltd. 1360 Peachtree Street, N.E. Atlanta, GA 30309 RE: Form 8-K Item 4.01 filed January 18, 2008 File #1-13908
Dear Mr. Carome: We have reviewed your response and have the following additional comments. Where indicated, we think you should revise your documents in res ponse to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplementa l information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review pr ocess is to assist you in your compliance with the applicable disclosure requirements and to e nhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter. 1. As previously requested, please amend your Item 4.01 Form 8-K to state whether the former accountant resigned, declined to stand for re-election or was dismissed, and the specific date, as required by Item 304(a)(1)(i) of Regulation S-K.
2. Please also remove the last sentence in the first paragraph of your Item 4.01 Form 8-K which states “the above-described engagement of Ernst & Young LLP (US) thus represents only a technical change of responsibility between members of the global Ernst & Young organization, and not an actual change in the Company’s accounting firm.”
3. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8-K.
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Kevin M. Carome General Counsel February 14, 2008 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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. Please file your supplemental response via EDGAR in response to these comments within 5 business days of the date of this letter. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. You may wish to provide us with marked copies of each amended filing to expedite our review. Direct any questions regarding the above to the undersigned at (202) 551-3866. Sincerely, Jeffrey Gordon Staff Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
February 14, 2008
Mr. Kevin M. Carome General Counsel Invesco Ltd. 1360 Peachtree Street, N.E. Atlanta, GA 30309
RE: Form 8-K Item 4.01 filed January 18, 2008
File #1-13908
Dear Mr. Carome: We have reviewed your response and have the following additional comments. Where indicated, we think you should revise your documents in res ponse to these comments. If you disagree, we
will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments,
we may ask you to provide us with supplementa l information so we may better understand your
disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review pr ocess is to assist you in your compliance with
the applicable disclosure requirements and to e nhance the overall disclosure in your filing. We
look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone
number listed at the end of this letter.
1. As previously requested, please amend your Item 4.01 Form 8-K to state whether the former accountant resigned, declined to stand for re-election or was dismissed, and the specific date, as required by Item 304(a)(1)(i) of Regulation S-K.
2. Please also remove the last sentence in the first paragraph of your Item 4.01 Form 8-K which states “the above-described engagement of Ernst & Young LLP (US) thus represents only a technical change of responsibility between members of the global Ernst & Young organization, and not an actual change in the Company’s accounting firm.”
3. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8-K.
*****
Kevin M. Carome
General Counsel February 14, 2008 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors
require. 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. Please file your supplemental response via EDGAR in response to these comments within 5 business days of the date of this letter. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. You may wish to provide us with marked copies of each amended filing to expedite our review. Direct
any questions regarding the above to the undersigned at (202) 551-3866. Sincerely, Jeffrey Gordon Staff Accountant