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SEC Company Response from Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — May 24, 2011

Invesco Ltd. (IVZ) (CIK 0000914208)
Date: May 24, 2011 · CIK: 0000914208 · Accession: 0000914208-11-000372

AI Filing Summary & Sentiment

Date
May 24, 2011
Author
/s/ Loren M. Starr
Form
CORRESP
Company
Invesco Ltd. (IVZ) (CIK 0000914208)

Letter

VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Invesco Ltd. FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2010 FORM 10-Q FOR THE PERIOD ENDED MARCH 31, 2011 FILE NUMBER: 1-13908

Dear Mr. Decker:

This letter sets forth the request of Invesco Ltd. (the “Company”) for an extension until July 1, 2011 of the deadline for our response to your comment letter, dated May 17, 2011, relating to the Annual Report on Form 10-K of the Company for the fiscal year ended December 31, 2010, filed with the Securities and Exchange Commission (the “Commission”) on February 25, 2011, and the Form 10-Q of the Company for the period ended March 31, 2011, filed with the Commission on April 29, 2011.

The Company would like to respond to the Commission’s comment letter by July 1, 2011. We believe that this additional time is needed to internally discuss and agree upon the Company’s disclosures that will be included in the Form 10-Q for the period ended June 30, 2011. You have requested that we include the form of our proposed future disclosure in our response letter.

If you have any questions regarding this letter, please do not hesitate to call me, Loren Starr, at (404) 479-2970.

Very truly yours,
/s/ Loren M. Starr

Show Raw Text
CORRESP
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filename1.htm

    corresp05242011.htm

                               May 24, 2011

VIA EDGAR

Mr. Rufus Decker

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E., Stop 4631

Washington, D.C. 20549

Invesco Ltd.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2010

FORM 10-Q FOR THE PERIOD ENDED MARCH 31, 2011

FILE NUMBER: 1-13908

Dear Mr. Decker:

This letter sets forth the request of Invesco Ltd. (the “Company”) for an extension until July 1, 2011 of the deadline for our response to your comment letter, dated May 17, 2011, relating to the Annual Report on Form 10-K of the Company for the fiscal year ended December 31, 2010, filed with the Securities and Exchange Commission (the “Commission”) on February 25, 2011, and the Form 10-Q of the Company for the period ended March 31, 2011, filed with the Commission on April 29, 2011.

The Company would like to respond to the Commission’s comment letter by July 1, 2011. We believe that this additional time is needed to internally discuss and agree upon the Company’s disclosures that will be included in the Form 10-Q for the period ended June 30, 2011.  You have requested that we include the form of our proposed future disclosure in our response letter.

If you have any questions regarding this letter, please do not hesitate to call me, Loren Starr, at (404) 479-2970.

 Very truly yours,

/s/ Loren M. Starr

      Loren M. Starr

      Chief Financial Officer

cc:           Ernst & Young LLP