SEC Company Response from MSX INTERNATIONAL INC (CIK 0001059274) — Jul 1, 2005
MSX INTERNATIONAL INC (CIK 0001059274)
Date: July 1, 2005 · CIK: 0001059274 · Accession: 0001169232-05-003429
AI Filing Summary & Sentiment
File numbers found in text: 333-49821
Referenced dates: June 15, 2005
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[LOGO] MSX
INTERNATIONAL
July 1, 2005
Mr. Larry Spirgel Division of Corporation Finance Securities and Exchange
Commission Washington, D.C. 20549
Re: MSX International, Inc.
Form 10-K for Fiscal Year Ended January 2, 2005 and
Form 10-Q for Fiscal Quarter Ended April 3, 2005
File No. 333-49821
Dear Mr. Spirgel:
In response to your letter dated June 15, 2005 we are providing the following
additional information with regards to our engineering service contracts and
associated revenue recognition policies:
SEC Comment:
Tell us in more detail about your engineering service contracts. Describe the
terms and duration of such contracts and tell us why you believe it is
appropriate to recognize such revenues using the percentage of completion
method.
Management Response:
Terms and duration - Engineering and design programs are generally 3 - 12
months in duration with the majority being less than 6 months. Program
costs primarily include direct labor and material costs based on the
quoted deliverables. The company has a history of project managing jobs
using percent completion and is able to reasonably estimate projected
costs. Changes in scope or deliverables are subject to a change order
approval process. Billing schedules are typically negotiated based upon
level of effort required throughout the program and customer payment
terms. Reimbursement for time and material costs incurred is required in
the event of early contract termination. Historically, contract
cancellations have been a rare occurrence. Revenues from such fixed price
programs totaled $19.5 million for the 2004 fiscal year. (3.5% of
consolidated revenue from continuing operations).
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Revenue recognition - Percent completion revenue is calculated based on
actual labor costs incurred on the program versus projected final labor
costs. Projections to complete the program are updated and evaluated by
management monthly. Material is treated as a pass through cost for revenue
recognition purposes. Material content varies by program and is not a
meaningful indicator of contract performance. Therefore, we recognize no
margin on material content during interim periods. Our services include
engineering design and product development functions which are covered by
paragraph 13 of SOP 81-1 regarding contracts for services performed by
engineers or engineering design firms. In accordance with SOP 81-1 and
subsequent staff accounting bulletins, we believe labor is the best
measure of performance of service based on the arrangements with our
customers and the nature of the deliverables. Our historical experience
supports this treatment.
In connection with the above response, we confirm the following:
o The company is responsible for the adequacy and accuracy of the
disclosures in our filings;
o Staff comments or changes to disclosure in response to staff comments do
not foreclose the Commission from taking any action with respect to the
company's filings; and
o The company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under federal securities laws of
the United States.
Sincerely,
/s/ Frederick K. Minturn
------------------------
Frederick K. Minturn
Executive Vice President and
Chief Financial Officer
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