SEC Comment Letter for Huron Consulting Group Inc. (HURN) (CIK 0001289848) (HURN) — Dec 29, 2011
Huron Consulting Group Inc. (HURN) (CIK 0001289848)
Date: Dec. 29, 2011 · CIK: 0001289848 · Accession: 0000000000-11-074187
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December 29, 2011
Via E-mail
Mr. C. Mark Hussey Executive Vice President, Chief Financial Officer and Treasurer Huron Consulting Group, Inc. 550 West Van Buren Street Chicago, IL 60607
Re: Huron Consulting Group, Inc.
Form 10-K for fiscal year ended December 31, 2010
Filed February 22, 2011 Form 10-Q for period ended September 30, 2011
Filed November 3, 2011 File No. 0-50976
Dear Mr. Hussey:
We have reviewed your filings and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments. Form 10-K for fiscal year ended December 31, 2010
Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 23
Contractual Obligations, page 48
1. Given that you note elsewhere that interest is based on a LIBOR spread or a base rate as
selected by you (as appears to be the case with your Amended and Restated Credit
Agreement entered into on April 14, 2011), it is unclear how you are unable to quantify
future obligations related to interest due on your borrowings. Ba sed on the significance
of your credit agreements, some level of quan titative information su rrounding the interest
obligations on your borrowings would be benefi cial to an investor. Please advise.
C. Mark Hussey Huron Consulting Group, Inc. December 29, 2011 Page 2
Form 10-Q for period ended September 30, 2011
Notes to Consolidated Financial Statements, page 5
10. Derivative Instrument and Hedging Activity, page 12
2. Please tell us how the entry into the Amende d and Restated Credit Agreement impacted
your outstanding interest rate swap agreement that is set to expire on February 23, 2012,
including how you determined there was no ineff ectiveness resulting from such change in
your variable-rate borrowings.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provi de a written statement from the company
acknowledging that:
the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
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 federa l securities laws of the United States.
You may contact Mark Raki p, Staff Accountant at 202.551.3573 or the undersigned at
202.551.3413 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
/s/ Cicely LaMothe
Cicely LaMothe Senior Assistant Chief Accountant