SEC Comment Letter for Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Aug 12, 2010
Invesco Ltd. (IVZ) (CIK 0000914208)
Date: Aug. 12, 2010 · CIK: 0000914208 · Accession: 0000000000-10-046324
AI Filing Summary & Sentiment
Referenced dates: July 16, 2010, June 11, 2010, June 11, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE August 12, 2010 Mr. Loren M. Starr Chief Financial Officer Invesco Ltd. 1555 Peachtree Street N.E., Suite 1800 Atlanta, Georgia 30309 RE: Invesco Ltd. Form 10-K for the Year Ended December 31, 2009 Forms 10-Q for the Periods Ended March 31, 2010 and June 30, 2010 Definitive Proxy Statement on Schedule 14A filed on March 29, 2010 Prospectus Supplement filed on May 20, 2009 File No. 1-13908
Dear Mr. Starr:
We have reviewed your response letter dated July 16, 2010 and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provi de in response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2009
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Assets Under Management, page 28
AUM by Channel, page 29
1. We have read your responses to comments f our and five from our letter dated June 11, 2010. Notwithstanding the fact that you ar e not a party to your investors’ asset
Mr. Loren M. Starr Invesco Ltd. August 12, 2010 Page 2 allocation decisions or decision-making pro cess, we would expect you to have some insight regarding the conditions of the financial market and your underlying product and services such that you can analyze and discuss the underl ying drivers of cash inflows and outflows of your AUM. Please provide a more robust discussion of the underlying reasons for changes in components of cash flows, market gain and losses/reinvestment and foreign currenc y translation by total AUM and AUM by channel. Please show us your proposed disclosures.
Results of Operations for the Year Ende d December 31, 2009, Compared with the Year Ended December 31, 2008, page 31 2. We have read your response to comment six from our letter dated June 11, 2010. Based on your consideration of comments f our and five from our letter dated June 11, 2010, please show us what your pr oposed disclosure will look like.
Form 10-Q for the Period Ended June 30, 2010
General 3. Please discuss the above comments in your interim filings as well.
Condensed Consolidated Statement of Changes in Equity, page 6
4. We have read your response to comment 15 from our letter dated June 11, 2010. Please note that we are still reviewing your response and we may have further comments when we have completed our review.
You may contact Ernest Greene, Staff A ccountant at (202) 551-3733 or Jeanne Baker, Assistant Chief A ccountant at (202) 551-3691 if you have questions regarding comments on the financial statements and related matters. Please contact Hagen Ganem, Staff Attorney at (202) 551-3330 or Dietrich King, Staff Attorney at (202) 551-3338 with any other questions.
Sincerely, R u f u s D e c k e r
Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
August 12, 2010
Mr. Loren M. Starr Chief Financial Officer Invesco Ltd. 1555 Peachtree Street N.E., Suite 1800 Atlanta, Georgia 30309
RE: Invesco Ltd.
Form 10-K for the Year Ended December 31, 2009 Forms 10-Q for the Periods Ended March 31, 2010 and
June 30, 2010
Definitive Proxy Statement on Schedule 14A filed on
March 29, 2010 Prospectus Supplement filed on May 20, 2009 File No. 1-13908
Dear Mr. Starr:
We have reviewed your response letter dated July 16, 2010 and have the following
comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your
response. After reviewing the information you provi de in response to these comments, we
may have additional comments.
Form 10-K for the Year Ended December 31, 2009
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Assets Under Management, page 28
AUM by Channel, page 29
1. We have read your responses to comments f our and five from our letter dated June
11, 2010. Notwithstanding the fact that you ar e not a party to your investors’ asset
Mr. Loren M. Starr
Invesco Ltd. August 12, 2010 Page 2
allocation decisions or decision-making pro cess, we would expect you to have some
insight regarding the conditions of the financial market and your underlying product
and services such that you can analyze and discuss the underl ying drivers of cash
inflows and outflows of your AUM. Please provide a more robust discussion of the
underlying reasons for changes in components of cash flows, market gain and losses/reinvestment and foreign currenc y translation by total AUM and AUM by
channel. Please show us your proposed disclosures.
Results of Operations for the Year Ende d December 31, 2009, Compared with the Year
Ended December 31, 2008, page 31
2. We have read your response to comment six from our letter dated June 11, 2010.
Based on your consideration of comments f our and five from our letter dated June
11, 2010, please show us what your pr oposed disclosure will look like.
Form 10-Q for the Period Ended June 30, 2010
General
3. Please discuss the above comments in your interim filings as well.
Condensed Consolidated Statement of Changes in Equity, page 6
4. We have read your response to comment 15 from our letter dated June 11, 2010.
Please note that we are still reviewing your response and we may have further
comments when we have completed our review.
You may contact Ernest Greene, Staff A ccountant at (202) 551-3733 or Jeanne
Baker, Assistant Chief A ccountant at (202) 551-3691 if you have questions regarding
comments on the financial statements and related matters. Please contact Hagen Ganem, Staff
Attorney at (202) 551-3330 or Dietrich King, Staff Attorney at (202) 551-3338 with any
other questions.
Sincerely, R u f u s D e c k e r
Accounting Branch Chief