SEC Comment Letter for AGRIUM INC (CIK 0000943003) — Jul 25, 2005
AGRIUM INC (CIK 0000943003)
Date: July 25, 2005 · CIK: 0000943003 · Accession: 0000000000-05-037885
AI Filing Summary & Sentiment
File numbers found in text: 001-14460
Referenced dates: June 22, 2005, June 9, 2005
Letter
June 29, 2005 Mr. Bruce G. Waterman Senior Vice President, Finance & Chief Financial Officer Agrium Inc. 13131 Lake Fraser Drive S.E. Calgary A0 T2J7E8 Canada
Re: Agrium Inc. Form 40-F for the Fiscal Year Ended December 31, 2004 Filed February 14, 2005 Response Letter Dated June 22, 2005 File No. 001-14460
Dear Mr. Waterman:
We have reviewed your response letter and have the following comment. Our review has been limited to those matters specifically addressed in this letter and the letter dated June 9, 2005. As indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation.
Form 40-F for the Fiscal Year Ended December 31, 2004
Evaluation of Disclosure Controls and Procedures, Page 3
1. We note your proposed statement that "disclosure controls and procedures provide a reasonable level of assurance that they are effective, they do not expect that the disclosure controls and procedures or internal control over financial reporting will prevent all errors and fraud. A control system, no matter how well conceived or operated, can provide only reasonable, not absolute, assurance that the objectives of the control system are met." Please revise to state clearly, if true, that your disclosure controls and procedures are designed to provide reasonable assurance of achieving their objectives and that your principal executive officer and principal financial officer concluded that your disclosure controls and procedures are effective at that reasonable assurance level. In the alternative, remove the reference to the level of assurance of your disclosure controls and procedures. Please refer to Section II.F.4 of Management`s Reports on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports, SEC Release No. 33-8238, available on our website at http://www.sec.gov/rules/final/33-8238.htm.
Closing Comments
As appropriate, please amend your filing and respond to this comment within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Yong Choi, Staff Accountant at (202) 551-3758 or Kim Calder, Assistant Chief Accountant at (202) 551-3701 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3684 with any other questions.
Sincerely,
April Sifford
Branch Chief
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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
June 29, 2005
Mr. Bruce G. Waterman
Senior Vice President, Finance & Chief Financial Officer
Agrium Inc.
13131 Lake Fraser Drive S.E.
Calgary A0 T2J7E8
Canada
Re: Agrium Inc.
Form 40-F for the Fiscal Year Ended December 31, 2004
Filed February 14, 2005
Response Letter Dated June 22, 2005
File No. 001-14460
Dear Mr. Waterman:
We have reviewed your response letter and have the following
comment. Our review has been limited to those matters
specifically
addressed in this letter and the letter dated June 9, 2005. As
indicated, we think you should revise your document in response to
this comment. If you disagree, we will consider your explanation
as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.
Form 40-F for the Fiscal Year Ended December 31, 2004
Evaluation of Disclosure Controls and Procedures, Page 3
1. We note your proposed statement that "disclosure controls and
procedures provide a reasonable level of assurance that they are
effective, they do not expect that the disclosure controls and
procedures or internal control over financial reporting will
prevent
all errors and fraud. A control system, no matter how well
conceived
or operated, can provide only reasonable, not absolute, assurance
that
the objectives of the control system are met." Please revise to
state
clearly, if true, that your disclosure controls and procedures are
designed to provide reasonable assurance of achieving their
objectives
and that your principal executive officer and principal financial
officer concluded that your disclosure controls and procedures are
effective at that reasonable assurance level. In the alternative,
remove the reference to the level of assurance of your disclosure
controls and procedures. Please refer to Section II.F.4 of
Management`s Reports on Internal Control Over Financial Reporting
and
Certification of Disclosure in Exchange Act Periodic Reports, SEC
Release No. 33-8238, available on our website at
http://www.sec.gov/rules/final/33-8238.htm.
Closing Comments
As appropriate, please amend your filing and respond to
this
comment within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the
amendment to expedite our review. Please understand that we may
have
additional comments after reviewing your amendment and responses
to
our comments.
You may contact Yong Choi, Staff Accountant at (202) 551-3758
or
Kim Calder, Assistant Chief Accountant at (202) 551-3701 if you
have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3684 with any other
questions.
Sincerely,
April Sifford
Branch Chief
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Mr. Bruce G. Waterman
Agrium Inc.
June 29, 2005
page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
</TEXT>
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