SEC Comment Letter for Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Oct 31, 2012
Invesco Ltd. (IVZ) (CIK 0000914208)
Date: Oct. 31, 2012 · CIK: 0000914208 · Accession: 0000000000-12-059612
AI Filing Summary & Sentiment
Letter
October 31 , 2012 Via E -Mail Mr. Loren M. Starr Senior Managing Director and C FO Invesco Ltd. 1555 Peachtree Street, N.E. Suite 1800 Atlanta, GA 30309
Re: Invesco Ltd. Form 10 -K for the Year Ended December 31, 2011 Filed February 24, 2012 File No. 1-13908
Dear Mr. Starr:
We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We u rge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Rufus Decker
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October 31 , 2012
Via E -Mail
Mr. Loren M. Starr
Senior Managing Director and C FO
Invesco Ltd.
1555 Peachtree Street, N.E.
Suite 1800
Atlanta, GA 30309
Re: Invesco Ltd.
Form 10 -K for the Year Ended December 31, 2011
Filed February 24, 2012
File No. 1-13908
Dear Mr. Starr:
We have completed our review of your filing. We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States. We u rge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing 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
Accounting Branch Chief