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SEC Comment Letter for QUANTA SERVICES, INC. (PWR) (CIK 0001050915) (PWR) — Jun 27, 2016

QUANTA SERVICES, INC. (PWR) (CIK 0001050915)
Date: June 27, 2016 · CIK: 0001050915 · Accession: 0000000000-16-082060

Revenue Recognition Financial Reporting Regulatory Compliance

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
June 27, 2016
Author
/s/ John Cash
Form
UPLOAD
Company
QUANTA SERVICES, INC. (PWR) (CIK 0001050915)

Letter

Mail Stop 4631 June 27, 2016 Via E -mail Mr. Derrick A. Jensen, Chief Financial Officer Quanta Services, Inc. 2800 Post Oak Boulevard, Suite 2600 Houston, TX 77056

Re: Quanta Services, Inc. Form 10-K for the year ended December 31, 2015 Filed February 29, 2016 File No. 1 -13831

Dear Mr. Jensen :

We have reviewed your May 26, 2016 response to our comment letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure.

Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to com ments in our April 28, 2016 letter .

Form 10 -K for the year ended December 31, 2015

Consolidated Financial Statements 2. Summary of Significant Accounting Policies, Revenue Recognition, page 98

1. We note your response to prior comment 4 from our let ter dated April 28, 2016. To the extent that material positive and negative changes in estimates offset each other in a period, please revise future filings to separately quan tify and disclose their impact. In addition, we note in MD&A you attribute decl ines in gross profit margins during the year ended December 31, 2015 to $73 million in contract losses you recorded during the period; however, we note no disclosures that indicate the contract losses were offset by positive changes in estimates on other c ontracts that you r ecorded during the same period.

Mr. Derrick A. Jensen Quanta Services, Inc. June 27, 2016 Page 2

Please revise MD&A in future filings to separately disclose and discuss the impact of material positive and negative changes in estimates during each period presented.

Form 8 -K filed on May 5, 2016

2. It appears to us you may not adequately explain why each non -GAAP financial measure you present is useful to investors and may not explain or properly present the tax effects of adjustments to your non -GAAP financial measures which may be inconsistent with the updated Compliance and Disclosure Interpre tations issued on May 17, 2016. Please review this guidance when preparing your next earnings release.

You may contact Mindy Hooker at (202) 551 -3732, Anne McConnell at (202) 551 -3709 or me at (202) 551 -3768 wi th any questions.

Sincerely,
/s/ John Cash

Show Raw Text
Mail Stop 4631
June 27, 2016

Via E -mail
Mr. Derrick A. Jensen, Chief Financial Officer
Quanta Services, Inc.
2800 Post Oak Boulevard, Suite 2600
Houston, TX  77056

Re: Quanta Services, Inc.
 Form 10-K for the year ended December 31, 2015
Filed February 29, 2016
File No. 1 -13831

Dear Mr. Jensen :

We have reviewed  your May 26, 2016  response to our comment  letter  and have the
following comment s.  In some of our comments , we may ask you to provide us with information
so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances, please  tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to com ments in our April 28,
2016  letter .

Form 10 -K for the year ended December 31, 2015

Consolidated Financial Statements
2. Summary of Significant Accounting  Policies, Revenue Recognition, page 98

1. We note your response to prior comment 4 from our let ter dated April 28, 2016.  To the
extent that material positive and negative changes in estimates offset each other in a
period, please revise future filings to separately quan tify and disclose their impact.  In
addition, we note in MD&A you attribute decl ines in gross profit margins during the year
ended December 31, 2015 to $73 million in contract losses you recorded during the
period; however, we note no disclosures that indicate the contract losses were offset by
positive changes in estimates on other c ontracts that you r ecorded during the same period.

Mr. Derrick A. Jensen
Quanta Services, Inc.
June 27, 2016
Page 2

 Please revise MD&A in future filings to separately disclose and discuss the impact of
material positive and negative changes in estimates during each period presented.

Form 8 -K filed on May 5, 2016

2. It appears to us you may not adequately explain why each non -GAAP financial measure
you present is useful to investors and may not explain or properly present the tax effects
of adjustments to your non -GAAP financial measures which may be inconsistent with the
updated Compliance and Disclosure Interpre tations issued on May 17, 2016.   Please
review this guidance when preparing your next earnings release.

You may contact Mindy Hooker at (202) 551 -3732, Anne McConnell at (202) 551 -3709
or me at (202) 551 -3768 wi th any questions.

Sincerely,

/s/ John Cash

John Cash
Branch Chief
Office of Manufacturing and
Construction