SEC Comment Letter for Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Jul 25, 2011
Invesco Ltd. (IVZ) (CIK 0000914208)
Date: July 25, 2011 · CIK: 0000914208 · Accession: 0000000000-11-044946
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July 25, 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 completed our review of your f ilings. We remind you that our comments or
changes to disclosure in res ponse to our comments do not fore close the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States. We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Rufus Decker
Rufus Decker
A c c o u n t i n g B r a n c h C h i e f