SEC Company Response from Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Oct 29, 2012
Invesco Ltd. (IVZ) (CIK 0000914208)
Date: Oct. 29, 2012 · CIK: 0000914208 · Accession: 0000914208-12-000523
AI Filing Summary & Sentiment
Referenced dates: July 17, 2012, October 18, 2012, October 25, 2012, SEPTEMBER 28, 2012
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission FORM 10-Q FOR THE PERIODS ENDED JUNE 30, 2012 RESPONSE LETTERS DATED SEPTEMBER 28, 2012, OCTOBER 4, 2012 AND OCTOBER 10, 2012 FILE NUMBER: 1-13908
Dear Mr. Decker:
This letter sets forth additional information requested of Invesco Ltd. (the “Company”) during a call with the Staff on Friday, October 26, 2012, in which the Staff discussed several comments regarding draft guarantor condensed consolidating financial information included in the Company's letter dated October 25, 2012. Each of the comments, as noted by the Company during the call, is indicated in this letter in italics, followed by the Company's response. We have continued to finalize the amounts disclosed in our draft guarantor condensed consolidating financial information based on these comments and look forward to discussing any additional comments with the Staff.
The Company is filing, via EDGAR, this additional information. The Company acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in its filings;
•
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to 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.
October 29, 2012
Mr. Rufus Decker
Page 2
Draft Revised Guarantor Condensed Consolidating Balance Sheet
1.
In the Adjustments column of the Draft Revised December 31, 2011 guarantor condensed consolidating balance sheet included in the Company's letter dated October 25, 2012, the Staff noted that the adjustment for the current intercompany receivables balance of $978.8 million was not the same offsetting balance as the current intercompany payables balance of $933.1 million and questioned why these numbers were not offsetting amounts.
Response to Comment 1
As discussed in our letter dated October 25, 2012, the numbers in our guarantor footnote were still under review and were marked draft. We have continued to finalize the numbers in advance of our impending amended filings, and we did identify one additional change to the December 31, 2011 condensed consolidating balance sheet information relating to the intercompany balance adjustments. As you noted, the adjustments for current intercompany receivables and payables should offset. We have reflected another set of guarantor financial information reflecting the current status of our draft as Appendix A to this letter.
Draft Revised Guarantor Condensed Consolidating Statements of Cash Flows
2.
There are new rows included in the Draft Revised Guarantor Condensed Consolidating Statements of Cash Flows in the October 25, 2011 presentation. These rows include the "Capital contribution (to)/from subsidiary" line item within the Investing section and the "Capital contribution from/(to) parent" line item within the Financing section. These rows were not included in the presentation of the condensed consolidating statement of cash flows for the year ended December 31, 2011 that was included in Appendix 2 of your response letter dated July 17, 2012. Where were the amounts in these new line items included in the presentation used in your letter dated July 17, 2012? How did the Company objectively determine that these cash flows were capital contributions and returns of capital instead of dividends? Explain why these cash flows do not appear to be consistent from period-to-period.
Response to Comment 2
As a result of the Staff's request in comment 2 of the letter dated October 18, 2012 that the Company reclassify intercompany loans and advances out of operating cash flows and reflect them in financing cash flows, the Company reviewed its prior presentation provided in Appendix 2 of our letter dated July 17, 2012 ("Appendix 2") of other intercompany capital transactions, including transactions in which parent entities within the consolidated group contribute capital to subsidiary entities and and subsidiary entities return capital back to the parent entities.
In Appendix 2, capital contribution cash outflows were disclosed within the investing section of the condensed consolidating statements of cash flows as "Purchase of other investments" or "Other net increases/(decreases) in investing activities" by the parent entities with the group. Returns of capital cash outflows from subsidiary entities to parent entities were also reflected by the subsidiaries within the investing section of the condensed consolidating statements of cash flows as "Other net increases/(decreases) in investing activities."
October 29, 2012
Mr. Rufus Decker
Page 3
In reviewing and challenging our prior disclosure, we determined that parent investments in subsidiary entities should be classified as investing cash outflows in accordance with ASC 230-10-45-13. Additionally, there is symmetry between the parent entity's cash flow presentation of capital contributions as investing activities and its balance sheet accounting for capital contributions, which reflects these transactions as increases to investment balances. When the investment is returned to the parent, the parent reflects the return as an investing cash inflow in accordance with ASC 230-10-45-12. Receipt and returns of capital, however, should be reflected as financing cash flows by the subsidiary entity in accordance with ASC 230-10-20 and 230-10-45-14 and 45-15.
We determined that the returns of capital from the subsidiaries were not dividend transactions through our review of the accounting treatment followed by the parent and subsidiary entities. The subsidiary entities had recorded the returns of capital as reductions of their capital accounts and not as reductions of retained earnings. Similarly, the parent entities had recorded the receipt of the returns of capital as reductions of their investments in the subsidiaries and not as dividend income.
As a result of the Staff's comments relating to the classification of intercompany balances and the presentation of intercompany cash flows in the guarantor condensed consolidating financial statements, the Company has developed additional review procedures for the preparation of this information. These procedures include reviewing the investment in subsidiary roll forwards for the parent entities, which will allow for the proper characterization of intercompany capital transactions between parent and subsidiaries. Additionally, a summary schedule is now being created listing all intercompany capital transactions to be used as a tracking and cash flow matching worksheet for the parent and subsidiary entities.
The Staff requested further explanation relating to the classification of certain capital transactions between entities within our consolidated group. These 2011 intercompany capital transactions are separately explained below.
1.
The Issuer invested new capital into a guarantor entity of $116.0 million. In Appendix 2, we reported this Issuer cash outflow as an investing outflow in the "Purchase of other investments" line item within the investing section in the Issuer column. The Guarantor entity who received the capital reported this cash receipt within operating activities (a positive $116.0 million was included in the $115.7). We had double-reported the receipt of the capital as an investing inflow by the non-Guarantors (a positive $116.0 million was included within the $27.2 million balance in "Purchase of other investments" in the non-guarantor column) and as a non-Guarantor operating cash outflow (a negative $116.0 million was included in the $488.4 million non-Guarantor cash provided by operating activities). This gross-up in the non-Guarantor column offset to zero in the non-Guarantor net cash flows.
In the cash flow information included in our October 25, 2012 letter, we corrected this presentation. The $116.0 million continues to be reflected within the investing section of the Issuer but is now separately presented as a capital contribution to a subsidiary. The receipt of this amount is reflected within the financing section of the Guarantor column as a cash inflow.
Please refer to the line items marked (C) in the reconciliations provided in response to comment 3 below for an illustration of the reclassifications relating to the $116.0 million.
October 29, 2012
Mr. Rufus Decker
Page 4
2. A non-guarantor entity returned capital of $61.0 million to the Issuer. In Appendix 2, we reported the Issuer cash inflow in the Issuer investing cash flows within the $62.5 million balance in the "Other net increases/(decreases) in investing activities" line item. The non-Guarantor similarly reflected the return of capital cash outflow in investing cash flows within the negative $27.9 million balance in the same line item.
In the draft cash flow information included in our October 25, 2012 letter, we reflected the non-Guarantor's return of capital as a cash outflow in the "Capital contribution (to)/from subsidiary" line item within the non-Guarantor's investing cash flows. We similarly reflected the $61.0 million as a positive balance in the Issuer's financing cash flows.
In the cash flow information included within this letter at Appendix A, the non-guarantor has now presented this return of capital as a financing cash outflow in the "Capital contribution from/(to) parent" line item.
Please refer to the line items marked (D) in the reconciliations provided in response to comment 3 below for an illustration of the reclassifications relating to the $61.0 million.
3.
The parent invested $23.1 million in several non-guarantor subsidiaries. In Appendix 2, we included this investment within the $25.6 million Parent cash outflow in the "Purchase of other investments" line item within the Parent's investing cash flows. The receipt of this capital was also reflected as an investing activity by the non-Guarantor subsidiary recipients and was included within the $27.2 million non-Guarantor cash inflow in the "Purchase of other investments" line item.
In the cash flow information included in our October 25, 2012 letter, the $23.1 million capital contribution is reflected in the Parent column within the investing section as a "Capital contribution (to)/from subsidiary," and in the non-Guarantor column within the financing section as a "Capital contribution from/(to) parent."
Please refer to the line items marked (E) in the reconciliations provided in response to comment 3 below for an illustration of the reclassifications relating to the $23.1 million.
Capital transactions between parent and subsidiary entities may differ from period-to-period. During our call on October 26, 2012, the Staff requested further explanation for certain 2010 intercompany capital transactions reflected in the condensed consolidating cash flow information that we presented in our October 25, 2012 letter. These transactions are further explained below.
1.
The Parent made two investments during the period: $62.7 million into the Issuer, and $140.4 million into non-Guarantor entities. Both of these investments were included as cash outflows within the positive $209.7 million balance in the "Capital contribution (to)/from subsidiary" line item in the Parent column.
The Issuer entity receiving the $62.7 million reflected this as a financing cash inflow in the "Capital contribution from/(to) parent" line item. The non-Guarantor entities receiving the $140.4 million reflected this as a financing cash inflow in this same line item. The $140.4 million positive number is included within the negative $272.4 million cash flow.
October 29, 2012
Mr. Rufus Decker
Page 5
2.
Non-Guarantor entities returned capital of $412.8 million to the Parent. The Parent is reflecting this as an investing cash inflow. Therefore, the $412.8 million inflow less the $62.7 million outflow less the $140.4 million outflow equal the positive $209.7 million balance in the Parent's "Capital contribution (to)/from subsidiary" line item. Likewise, in the non-Guarantor financing section, the $412.8 million cash outflow less the $140.4 million cash inflow discussed above equals the $272.4 million balance in the non-Guarantor's "Capital contribution from/(to) parent" line item.
3.
Provide a reconciliation of the cash flows from operating activities reported in the Company's 2011 Form 10-K filed on February 24, 2012, to the balances presented as cash flows from operating activities in the Draft Guarantor Condensed Consolidating Statement of Cash Flows in the Company's letter dated October 25, 2012. Provide a reconciliation of cash flows from investing activities reported in Appendix 2 of the Company's July 17, 2012 letter to the balances presented as cash flows from investing activities in the Company's October 25, 2012 letter.
Response to Comment 3
The requested reconciliations are presented below. Reconciling items primarily relate to the reclassifications made to properly reflect the capital transactions discussed in our response to comment 2 above. Additionally, we have reclassified intercompany loans and advances from operating cash flows and into financing cash flows, as requested by the Staff in comment 2 of their letter dated October 18, 2012.
We attach an updated draft of our full condensed consolidating guarantor financial statements to be contained in our 2011 Form 10-K/A at Appendix A of this letter.
October 29, 2012
Mr. Rufus Decker
Page 6
Reconciliation of Changes to Guarantor Condensed Consolidating Statements of Cash Flows
$ in millions
Guarantors
Non-Guarantors
Issuer
Parent
Adjustments
Consolidated
Year ended December 31, 2011
Operating activities:
Net cash provided by/(used in) operating activities, as reported in the 2011 Form 10-K
115.7
536.8
55.5
650.3
(393.5
)
964.8
Reclassifications:
(A) Dividend
—
(48.4
)
48.4
—
—
—
Net cash provided by/(used in) operating activities, as reported in Appendix 2 of the Company's July 17, 2012 letter
115.7
488.4
103.9
650.3
(393.5
)
964.8
Reclassifications:
(B) Reclassification of intercompany loans
299.9
69.1
(107.7
)
(261.3
)
—
—
(C) New capital invested from Issuer to guarantor
(116.0
)
116.0
—
—
—
—
Other
—
(0.1
)
0.1
—
—
—
Net cash provided by/(used in) operating activities, as reported in the Company's October 25, 2012 letter and as reported in Appendix A of this letter
299.6
673.4
(3.7
)
389.0
(393.5
)
964.8
Investing activities:
Net cash provided by/(used in) investing activities, as reported in the Company's 2011 Form 10-K and as reported in Appendix 2 of the Company's July 17, 2012 letter
(76.5
)
486.9
(53.5
)
(6.3
)
(2.5
)
348.1
Reclassifications:
(C) New capital invested from Issuer to Guarantor
—
(116.0
)
—
—
116.0
—
(D) Return of capital from non-Guarantor to Issuer
—
(61.0
)
—
61.0
—
(E) New investment from Parent to non-Guarantor
—
(23.1
)
—
—
23.1
—
Other
—
(2.5
)
—
—
2.5
—
Net cash provided by/(used in) investing activities, as reported in the Company's October 25, 2012 letter
(76.5
)
345.3
(114.5
)
(6.3
)
200.1
348.1
Reclassifications:
(D) Return of capital from non-Guarantor to Issuer
—
61.0
61.0
—
(122.0
)
—
Net cash provided by/(used in) investing activities, as reported in Appendix A of this letter
(76.5
)
406.3
(53.5
)
(6.3
)
78.1
348.1
Please see the footnotes to this table on the next page.
Show Raw Text
CORRESP
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filename1.htm
Round 3 (B) Response
October 29, 2012
VIA EDGAR
Mr. Rufus Decker
Division of Corporation Finance
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Invesco Ltd.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2011
FORM 10-Q FOR THE PERIODS ENDED JUNE 30, 2012
RESPONSE LETTERS DATED SEPTEMBER 28, 2012, OCTOBER 4, 2012 AND
OCTOBER 10, 2012
FILE NUMBER: 1-13908
Dear Mr. Decker:
This letter sets forth additional information requested of Invesco Ltd. (the “Company”) during a call with the Staff on Friday, October 26, 2012, in which the Staff discussed several comments regarding draft guarantor condensed consolidating financial information included in the Company's letter dated October 25, 2012. Each of the comments, as noted by the Company during the call, is indicated in this letter in italics, followed by the Company's response. We have continued to finalize the amounts disclosed in our draft guarantor condensed consolidating financial information based on these comments and look forward to discussing any additional comments with the Staff.
The Company is filing, via EDGAR, this additional information. The Company acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in its filings;
•
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to 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.
October 29, 2012
Mr. Rufus Decker
Page 2
Draft Revised Guarantor Condensed Consolidating Balance Sheet
1.
In the Adjustments column of the Draft Revised December 31, 2011 guarantor condensed consolidating balance sheet included in the Company's letter dated October 25, 2012, the Staff noted that the adjustment for the current intercompany receivables balance of $978.8 million was not the same offsetting balance as the current intercompany payables balance of $933.1 million and questioned why these numbers were not offsetting amounts.
Response to Comment 1
As discussed in our letter dated October 25, 2012, the numbers in our guarantor footnote were still under review and were marked draft. We have continued to finalize the numbers in advance of our impending amended filings, and we did identify one additional change to the December 31, 2011 condensed consolidating balance sheet information relating to the intercompany balance adjustments. As you noted, the adjustments for current intercompany receivables and payables should offset. We have reflected another set of guarantor financial information reflecting the current status of our draft as Appendix A to this letter.
Draft Revised Guarantor Condensed Consolidating Statements of Cash Flows
2.
There are new rows included in the Draft Revised Guarantor Condensed Consolidating Statements of Cash Flows in the October 25, 2011 presentation. These rows include the "Capital contribution (to)/from subsidiary" line item within the Investing section and the "Capital contribution from/(to) parent" line item within the Financing section. These rows were not included in the presentation of the condensed consolidating statement of cash flows for the year ended December 31, 2011 that was included in Appendix 2 of your response letter dated July 17, 2012. Where were the amounts in these new line items included in the presentation used in your letter dated July 17, 2012? How did the Company objectively determine that these cash flows were capital contributions and returns of capital instead of dividends? Explain why these cash flows do not appear to be consistent from period-to-period.
Response to Comment 2
As a result of the Staff's request in comment 2 of the letter dated October 18, 2012 that the Company reclassify intercompany loans and advances out of operating cash flows and reflect them in financing cash flows, the Company reviewed its prior presentation provided in Appendix 2 of our letter dated July 17, 2012 ("Appendix 2") of other intercompany capital transactions, including transactions in which parent entities within the consolidated group contribute capital to subsidiary entities and and subsidiary entities return capital back to the parent entities.
In Appendix 2, capital contribution cash outflows were disclosed within the investing section of the condensed consolidating statements of cash flows as "Purchase of other investments" or "Other net increases/(decreases) in investing activities" by the parent entities with the group. Returns of capital cash outflows from subsidiary entities to parent entities were also reflected by the subsidiaries within the investing section of the condensed consolidating statements of cash flows as "Other net increases/(decreases) in investing activities."
October 29, 2012
Mr. Rufus Decker
Page 3
In reviewing and challenging our prior disclosure, we determined that parent investments in subsidiary entities should be classified as investing cash outflows in accordance with ASC 230-10-45-13. Additionally, there is symmetry between the parent entity's cash flow presentation of capital contributions as investing activities and its balance sheet accounting for capital contributions, which reflects these transactions as increases to investment balances. When the investment is returned to the parent, the parent reflects the return as an investing cash inflow in accordance with ASC 230-10-45-12. Receipt and returns of capital, however, should be reflected as financing cash flows by the subsidiary entity in accordance with ASC 230-10-20 and 230-10-45-14 and 45-15.
We determined that the returns of capital from the subsidiaries were not dividend transactions through our review of the accounting treatment followed by the parent and subsidiary entities. The subsidiary entities had recorded the returns of capital as reductions of their capital accounts and not as reductions of retained earnings. Similarly, the parent entities had recorded the receipt of the returns of capital as reductions of their investments in the subsidiaries and not as dividend income.
As a result of the Staff's comments relating to the classification of intercompany balances and the presentation of intercompany cash flows in the guarantor condensed consolidating financial statements, the Company has developed additional review procedures for the preparation of this information. These procedures include reviewing the investment in subsidiary roll forwards for the parent entities, which will allow for the proper characterization of intercompany capital transactions between parent and subsidiaries. Additionally, a summary schedule is now being created listing all intercompany capital transactions to be used as a tracking and cash flow matching worksheet for the parent and subsidiary entities.
The Staff requested further explanation relating to the classification of certain capital transactions between entities within our consolidated group. These 2011 intercompany capital transactions are separately explained below.
1.
The Issuer invested new capital into a guarantor entity of $116.0 million. In Appendix 2, we reported this Issuer cash outflow as an investing outflow in the "Purchase of other investments" line item within the investing section in the Issuer column. The Guarantor entity who received the capital reported this cash receipt within operating activities (a positive $116.0 million was included in the $115.7). We had double-reported the receipt of the capital as an investing inflow by the non-Guarantors (a positive $116.0 million was included within the $27.2 million balance in "Purchase of other investments" in the non-guarantor column) and as a non-Guarantor operating cash outflow (a negative $116.0 million was included in the $488.4 million non-Guarantor cash provided by operating activities). This gross-up in the non-Guarantor column offset to zero in the non-Guarantor net cash flows.
In the cash flow information included in our October 25, 2012 letter, we corrected this presentation. The $116.0 million continues to be reflected within the investing section of the Issuer but is now separately presented as a capital contribution to a subsidiary. The receipt of this amount is reflected within the financing section of the Guarantor column as a cash inflow.
Please refer to the line items marked (C) in the reconciliations provided in response to comment 3 below for an illustration of the reclassifications relating to the $116.0 million.
October 29, 2012
Mr. Rufus Decker
Page 4
2. A non-guarantor entity returned capital of $61.0 million to the Issuer. In Appendix 2, we reported the Issuer cash inflow in the Issuer investing cash flows within the $62.5 million balance in the "Other net increases/(decreases) in investing activities" line item. The non-Guarantor similarly reflected the return of capital cash outflow in investing cash flows within the negative $27.9 million balance in the same line item.
In the draft cash flow information included in our October 25, 2012 letter, we reflected the non-Guarantor's return of capital as a cash outflow in the "Capital contribution (to)/from subsidiary" line item within the non-Guarantor's investing cash flows. We similarly reflected the $61.0 million as a positive balance in the Issuer's financing cash flows.
In the cash flow information included within this letter at Appendix A, the non-guarantor has now presented this return of capital as a financing cash outflow in the "Capital contribution from/(to) parent" line item.
Please refer to the line items marked (D) in the reconciliations provided in response to comment 3 below for an illustration of the reclassifications relating to the $61.0 million.
3.
The parent invested $23.1 million in several non-guarantor subsidiaries. In Appendix 2, we included this investment within the $25.6 million Parent cash outflow in the "Purchase of other investments" line item within the Parent's investing cash flows. The receipt of this capital was also reflected as an investing activity by the non-Guarantor subsidiary recipients and was included within the $27.2 million non-Guarantor cash inflow in the "Purchase of other investments" line item.
In the cash flow information included in our October 25, 2012 letter, the $23.1 million capital contribution is reflected in the Parent column within the investing section as a "Capital contribution (to)/from subsidiary," and in the non-Guarantor column within the financing section as a "Capital contribution from/(to) parent."
Please refer to the line items marked (E) in the reconciliations provided in response to comment 3 below for an illustration of the reclassifications relating to the $23.1 million.
Capital transactions between parent and subsidiary entities may differ from period-to-period. During our call on October 26, 2012, the Staff requested further explanation for certain 2010 intercompany capital transactions reflected in the condensed consolidating cash flow information that we presented in our October 25, 2012 letter. These transactions are further explained below.
1.
The Parent made two investments during the period: $62.7 million into the Issuer, and $140.4 million into non-Guarantor entities. Both of these investments were included as cash outflows within the positive $209.7 million balance in the "Capital contribution (to)/from subsidiary" line item in the Parent column.
The Issuer entity receiving the $62.7 million reflected this as a financing cash inflow in the "Capital contribution from/(to) parent" line item. The non-Guarantor entities receiving the $140.4 million reflected this as a financing cash inflow in this same line item. The $140.4 million positive number is included within the negative $272.4 million cash flow.
October 29, 2012
Mr. Rufus Decker
Page 5
2.
Non-Guarantor entities returned capital of $412.8 million to the Parent. The Parent is reflecting this as an investing cash inflow. Therefore, the $412.8 million inflow less the $62.7 million outflow less the $140.4 million outflow equal the positive $209.7 million balance in the Parent's "Capital contribution (to)/from subsidiary" line item. Likewise, in the non-Guarantor financing section, the $412.8 million cash outflow less the $140.4 million cash inflow discussed above equals the $272.4 million balance in the non-Guarantor's "Capital contribution from/(to) parent" line item.
3.
Provide a reconciliation of the cash flows from operating activities reported in the Company's 2011 Form 10-K filed on February 24, 2012, to the balances presented as cash flows from operating activities in the Draft Guarantor Condensed Consolidating Statement of Cash Flows in the Company's letter dated October 25, 2012. Provide a reconciliation of cash flows from investing activities reported in Appendix 2 of the Company's July 17, 2012 letter to the balances presented as cash flows from investing activities in the Company's October 25, 2012 letter.
Response to Comment 3
The requested reconciliations are presented below. Reconciling items primarily relate to the reclassifications made to properly reflect the capital transactions discussed in our response to comment 2 above. Additionally, we have reclassified intercompany loans and advances from operating cash flows and into financing cash flows, as requested by the Staff in comment 2 of their letter dated October 18, 2012.
We attach an updated draft of our full condensed consolidating guarantor financial statements to be contained in our 2011 Form 10-K/A at Appendix A of this letter.
October 29, 2012
Mr. Rufus Decker
Page 6
Reconciliation of Changes to Guarantor Condensed Consolidating Statements of Cash Flows
$ in millions
Guarantors
Non-Guarantors
Issuer
Parent
Adjustments
Consolidated
Year ended December 31, 2011
Operating activities:
Net cash provided by/(used in) operating activities, as reported in the 2011 Form 10-K
115.7
536.8
55.5
650.3
(393.5
)
964.8
Reclassifications:
(A) Dividend
—
(48.4
)
48.4
—
—
—
Net cash provided by/(used in) operating activities, as reported in Appendix 2 of the Company's July 17, 2012 letter
115.7
488.4
103.9
650.3
(393.5
)
964.8
Reclassifications:
(B) Reclassification of intercompany loans
299.9
69.1
(107.7
)
(261.3
)
—
—
(C) New capital invested from Issuer to guarantor
(116.0
)
116.0
—
—
—
—
Other
—
(0.1
)
0.1
—
—
—
Net cash provided by/(used in) operating activities, as reported in the Company's October 25, 2012 letter and as reported in Appendix A of this letter
299.6
673.4
(3.7
)
389.0
(393.5
)
964.8
Investing activities:
Net cash provided by/(used in) investing activities, as reported in the Company's 2011 Form 10-K and as reported in Appendix 2 of the Company's July 17, 2012 letter
(76.5
)
486.9
(53.5
)
(6.3
)
(2.5
)
348.1
Reclassifications:
(C) New capital invested from Issuer to Guarantor
—
(116.0
)
—
—
116.0
—
(D) Return of capital from non-Guarantor to Issuer
—
(61.0
)
—
61.0
—
(E) New investment from Parent to non-Guarantor
—
(23.1
)
—
—
23.1
—
Other
—
(2.5
)
—
—
2.5
—
Net cash provided by/(used in) investing activities, as reported in the Company's October 25, 2012 letter
(76.5
)
345.3
(114.5
)
(6.3
)
200.1
348.1
Reclassifications:
(D) Return of capital from non-Guarantor to Issuer
—
61.0
61.0
—
(122.0
)
—
Net cash provided by/(used in) investing activities, as reported in Appendix A of this letter
(76.5
)
406.3
(53.5
)
(6.3
)
78.1
348.1
Please see the footnotes to this table on the next page.