SEC Comment Letter for Huron Consulting Group Inc. (HURN) (CIK 0001289848) (HURN) — Jul 22, 2013
Huron Consulting Group Inc. (HURN) (CIK 0001289848)
Date: July 22, 2013 · CIK: 0001289848 · Accession: 0000000000-13-039948
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File numbers found in text: 000-50976
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July 22 , 2013 Via E-mail C. Mark Hussey Executive Vice President , Chief Financial Officer and Treasurer Huron Consulting Group Inc. 550 West Van Buren Street Chicago, Illinois 60 607 Re: Huron Consulting Group Inc. Form 10 -K for the year ended December 31, 2012 Filed on February 2 1, 2013 File No. 000-50976 Dear Mr. Hussey : We have reviewed your filing an d have the following comment s. In our comment s, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter via EDGAR within ten business days by provi ding the requested information or by advising us when you will provide the requested response. If you do not believe ou r comment s apply to your facts and circumstances , please tell us why in your response. After reviewing the information you provide in response to these comment s, we may have additional comments. Form 10 -K for the Year Ended December 31, 2012 Management’s Discussion and Analysis of Financial Condition, page 24 Year Ended December 31, 2012 compared to Year Ended December 31, 2013, page 35 Other Expense net, page 37 1) Please tell us the nature of the investments used to fund your deferred compen sation plan and where these investments have been included in your financial statements. C. Mark Hussey Huron Consulting Group Inc. July 22 , 2013 Page 2 Financial Statements Notes to Consolidated Financial Statements, page F -7 14. Equity Incentive Plans, page F -28 2) We note your disclosure of total share based compensation costs recognized for the years ended December 31, 2012, 2011 and 2010. Please tell us how these amounts reconcile to those presented on your Consolidated Statements of Stockholder’s Equity and Cash Flows. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. 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 comment s, please provide a written statement fr om the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States. You may contact Shannon Sobotka, Staff Accountant, at ( 202) 551 -3856 or the undersigned at (202) 551 -3438 if you have questions regarding comments on the financial statements and related matters. Please contact Beth Frohlichstein , Attorney Advisor, at (202) 551 -3789 or Stacie Gorman , Attorney Advisor at (202) 551-3585 with regard to legal comments. Sincerely, /s/ Robert F. Telewicz Jr. Robert F. Telewicz Jr. Senior Staff Accountant