SEC Comment Letter for Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Jul 15, 2011
Invesco Ltd. (IVZ) (CIK 0000914208)
Date: July 15, 2011 · CIK: 0000914208 · Accession: 0000000000-11-043094
AI Filing Summary & Sentiment
Referenced dates: June 30, 2011, May 17, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE July 15, 2011 Via Facsimile 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, 2010 Filed February 25, 2011 Form 10-Q for the Period Ended March 31, 2011 Filed April 29, 2011 File No. 1-13908
Dear Mr. Starr:
We have reviewed your response letter dated June 30, 2011 and have the following comment. In our comment, we may ask you to pr ovide 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 comment applies to your facts a nd circumstances, 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 Year Ended December 31, 2010
Financial Statements
19. Commitments and Contingencies, page 129
Legal Contingencies, page 130
1. We have read your response to comment four from our letter dated May 17, 2011. While we understand that the nature of litigation make s it difficult to predict with certainty the eventual outcome of a case or claim, AS C 450-20-50 does require disclosure of an estimated range of reasonably possible losses for legal contingencies where it is possible
Mr. Loren M. Starr Invesco Ltd. July 15, 2011 Page 2 to make such an estimate. In future fili ngs, please expand your disclosures in a similar manner to your response to state, if true, that it is not possible to estimate the range of reasonably possible losses as it rela tes to your legal contingencies.
You may contact Ernest Greene, Staff A ccountant at (202) 551-3733 or Lisa Etheredge, Staff Accountant at (202) 551-3424 if you have questions regarding comments on the financial statements and related matters.
Sincerely, / s / R u f u s D e c k e r R u f u s D e c k e r
Accounting Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
July 15, 2011
Via Facsimile
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, 2010
Filed February 25, 2011 Form 10-Q for the Period Ended March 31, 2011 Filed April 29, 2011 File No. 1-13908
Dear Mr. Starr:
We have reviewed your response letter dated June 30, 2011 and have the following
comment. In our comment, we may ask you to pr ovide 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 comment applies to your facts a nd circumstances, 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 Year Ended December 31, 2010
Financial Statements
19. Commitments and Contingencies, page 129
Legal Contingencies, page 130
1. We have read your response to comment four from our letter dated May 17, 2011. While
we understand that the nature of litigation make s it difficult to predict with certainty the
eventual outcome of a case or claim, AS C 450-20-50 does require disclosure of an
estimated range of reasonably possible losses for legal contingencies where it is possible
Mr. Loren M. Starr
Invesco Ltd. July 15, 2011 Page 2
to make such an estimate. In future fili ngs, please expand your disclosures in a similar
manner to your response to state, if true, that it is not possible to estimate the range of
reasonably possible losses as it rela tes to your legal contingencies.
You may contact Ernest Greene, Staff A ccountant at (202) 551-3733 or Lisa Etheredge,
Staff Accountant at (202) 551-3424 if you have questions regarding comments on the financial
statements and related matters.
Sincerely, / s / R u f u s D e c k e r R u f u s D e c k e r
Accounting Branch Chief