SEC Comment Letter for Waste Connections, Inc. (WCN) (CIK 0001318220) (WCN) — Jul 9, 2018
Waste Connections, Inc. (WCN) (CIK 0001318220)
Date: July 9, 2018 · CIK: 0001318220 · Accession: 0000000000-18-020977
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34370
Letter
July 9, 2018 Worthing Jackman Executive Vice President and Chief Financial Officer Waste Connections, Inc. 610 Applewood Crescent, 2nd Floor Vaughan Ontario, L4K 0E3 Canada Re:Waste Connections, Inc. Form 10-Q for Fiscal Quarter Ended March 31, 2018 Filed May 2, 2018 File No. 001-34370 Dear Mr. Jackman: We have reviewed your filing 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 these comments 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 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. Form 10-Q for the Fiscal Quarter Ended March 31, 2018 3. New Accounting Standards Revenue From Contracts With Customers, page 7 1.We note your disclosures on page 7 for the adoption of ASC 606, which appear to substantially replicate the disclosures you provided on page 99 of your 2017 Form 10-K in accordance with SAB 74 rather than the disclosures required by ASC 606-10-50. Please tell us your considerations of the disclosures set forth in ASC 606-10-50 (e.g. disaggregated revenue, explanations of your performance obligations, transaction price allocated to remaining performance obligations, significant judgements applied, determining the timing of satisfaction of each performance obligation, election of practical
FirstName LastNameWorthing Jackman Comapany NameWaste Connections, Inc. July 9, 2018 Page 2 FirstName LastName Worthing Jackman Waste Connections, Inc. July 9, 2018 Page 2 expedients, etc.). We remind you of the guidance in Rule 10-01(a)(5) of Regulation S-X, which would elicit both annual and interim periods financial statement disclosures prescribed by new accounting principles and practice in each quarterly report in the year of adoption. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744, or Tracey Houser, Staff Accountant, at (202) 551-3736, if you have questions regarding comments on the financial statements and related matters. Please contact Terence O'Brien, Branch Chief, at (202) 551-3355 with any other questions. Division of Corporation Finance Office of Manufacturing and Construction
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July 9, 2018
Worthing Jackman
Executive Vice President and Chief Financial Officer
Waste Connections, Inc.
610 Applewood Crescent, 2nd Floor
Vaughan
Ontario, L4K 0E3
Canada
Re:Waste Connections, Inc.
Form 10-Q for Fiscal Quarter Ended March 31, 2018
Filed May 2, 2018
File No. 001-34370
Dear Mr. Jackman:
We have reviewed your filing 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 these comments 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
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.
Form 10-Q for the Fiscal Quarter Ended March 31, 2018
3. New Accounting Standards
Revenue From Contracts With Customers, page 7
1.We note your disclosures on page 7 for the adoption of ASC 606, which appear to
substantially replicate the disclosures you provided on page 99 of your 2017 Form 10-K in
accordance with SAB 74 rather than the disclosures required by ASC 606-10-50. Please
tell us your considerations of the disclosures set forth in ASC 606-10-50 (e.g.
disaggregated revenue, explanations of your performance obligations, transaction price
allocated to remaining performance obligations, significant judgements applied,
determining the timing of satisfaction of each performance obligation, election of practical
FirstName LastNameWorthing Jackman
Comapany NameWaste Connections, Inc.
July 9, 2018 Page 2
FirstName LastName
Worthing Jackman
Waste Connections, Inc.
July 9, 2018
Page 2
expedients, etc.). We remind you of the guidance in Rule 10-01(a)(5) of Regulation S-X,
which would elicit both annual and interim periods financial statement disclosures
prescribed by new accounting principles and practice in each quarterly report in the year
of adoption.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744, or Tracey Houser,
Staff Accountant, at (202) 551-3736, if you have questions regarding comments on the financial
statements and related matters. Please contact Terence O'Brien, Branch Chief, at (202) 551-3355
with any other questions.
Division of Corporation Finance
Office of Manufacturing and
Construction