SEC Comment Letter for Waste Connections, Inc. (WCN) (CIK 0001318220) (WCN) — Dec 22, 2015
Waste Connections, Inc. (WCN) (CIK 0001318220)
Date: Dec. 22, 2015 · CIK: 0001318220 · Accession: 0000000000-15-059194
AI Filing Summary & Sentiment
Reasoning
Referenced dates: November 23, 2015
Letter
Mail Stop 4631 December 22, 2015 Via E -mail Mr. Ian Kidson Executive Vice -President and Chief Financial Officer 400 Applewood Crescent, 2nd Floor Vaughan, Ontario L4K 0C3, Canada
Re: Progressive Waste Solutions, Ltd. Form 40-F Filed March 30, 2015 File No. 1-34370
Dear Mr. Kidson :
We have reviewed your response dated December 8, 2015, and have the following comment. Please respond to this letter within ten business days by providing the requested information, or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your re sponse. After reviewing your response to this comment , we may have additional comments.
Form 6 -K filed July 30, 2015
Exhibit 99.1
Critical Accounting Estimates, page 41
1. We have read your response to comment 1 in our letter dated November 23, 2015. Please highlight in your disclosures where applicable that absent the reorganization of your management structure, the former U.S. northeast reporting unit would have been expected to continue to fail step one of the goodwill impairment test.
You may contact Jenn Do at (202) 551-3743 or me at (202) 551-3355 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Terence O ’Brien
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Mail Stop 4631 December 22, 2015 Via E -mail Mr. Ian Kidson Executive Vice -President and Chief Financial Officer 400 Applewood Crescent, 2nd Floor Vaughan, Ontario L4K 0C3, Canada Re: Progressive Waste Solutions, Ltd. Form 40-F Filed March 30, 2015 File No. 1-34370 Dear Mr. Kidson : We have reviewed your response dated December 8, 2015, and have the following comment. Please respond to this letter within ten business days by providing the requested information, or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your re sponse. After reviewing your response to this comment , we may have additional comments. Form 6 -K filed July 30, 2015 Exhibit 99.1 Critical Accounting Estimates, page 41 1. We have read your response to comment 1 in our letter dated November 23, 2015. Please highlight in your disclosures where applicable that absent the reorganization of your management structure, the former U.S. northeast reporting unit would have been expected to continue to fail step one of the goodwill impairment test. You may contact Jenn Do at (202) 551-3743 or me at (202) 551-3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Terence O ’Brien Terence O’Brien Branch Chief Office of Manufacturing and Construction