SEC Comment Letter for Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Oct 9, 2013
Invesco Ltd. (IVZ) (CIK 0000914208)
Date: Oct. 9, 2013 · CIK: 0000914208 · Accession: 0000000000-13-055811
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October 9, 2013 Via E -mail Martin L. Flanagan President and Chief Executive Officer Invesco Ltd. 1555 Peachtree Street, N.E., Suite 1800 Atlanta, GA 30309 Re: Invesco Ltd. Form 10 -K for the Fiscal Year Ended Decem ber 31, 2012 Filed February 22, 2013 File No. 001 -13908 Dear Mr. Flanagan : We have com pleted 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 fr om 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 urge all perso ns who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Laura Crotty for Suzanne Hayes Assistant Director