SEC Company Response from Waste Connections, Inc. (WCN) (CIK 0001318220) (WCN) — Dec 21, 2011
Waste Connections, Inc. (WCN) (CIK 0001318220)
Date: Dec. 21, 2011 · CIK: 0001318220 · Accession: 0001104659-11-070694
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 9, 2011
Letter
Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-4631 Attention: Rufus Decker, Accounting Branch Chief Division of Corporate Finance And: Nudrat Salik, Staff Accountant Division of Corporate Fianace
Dear Sir/Madame:
Re: Progressive Waste Solutions Ltd.
Form 40-F for Year ended December 31, 2010
Filed March 31, 2011
File No. 1-34370
Set forth below are the responses of Progressive Waste Solutions Ltd. to the comments of the Staff of the Securities and Exchange Commission regarding the above-referenced filing as set forth in the letter dated December 9, 2011. We have repeated the comments and followed each comment with our response.
Form 40-F for Year ended December 31, 2010
General
1. General instruction B(3) of the Form 40-F requires you to file audited annual financial statements and accompanying management’s discussion and analysis under the cover of the Form 40-F. In future filings, please provide the audited financial statements and accompanying management’s discussion and analysis in your Form 40-F rather than incorporating by reference these items into your Form 40-F. Alternatively, you may file these items as exhibits to the Form 40-F.
Company Response:
In future filings, we will provide the audited financial statements and accompanying management’s discussion and analysis in the Form 40-F or file these items as exhibits to the Form 40-F.
In addition, as requested in your letter of December 9, 2011, we confirm that:
· We are responsible for the adequacy and accuracy of the disclosure in our 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
· We 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.
Yours truly,
Progressive Waste Solutions Ltd.
/s/ Thomas J. Cowee
Thomas J. Cowee
Vice President and Chief Financial Officer
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CORRESP 1 filename1.htm 400 Applewood Crescent, 2nd Floor Vaughan, ON L4K 0C3 T: 905 532 7510 F: 905 532 7576 www.progressivewaste.com Thomas J. Cowee Vice President & Chief Fiancial Officer Direct: 905-532-7521 Email: tom.cowee@progressivewaste.com December 20, 2011 Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-4631 Attention: Rufus Decker, Accounting Branch Chief Division of Corporate Finance And: Nudrat Salik, Staff Accountant Division of Corporate Fianace Dear Sir/Madame: Re: Progressive Waste Solutions Ltd. Form 40-F for Year ended December 31, 2010 Filed March 31, 2011 File No. 1-34370 Set forth below are the responses of Progressive Waste Solutions Ltd. to the comments of the Staff of the Securities and Exchange Commission regarding the above-referenced filing as set forth in the letter dated December 9, 2011. We have repeated the comments and followed each comment with our response. Form 40-F for Year ended December 31, 2010 General 1. General instruction B(3) of the Form 40-F requires you to file audited annual financial statements and accompanying management’s discussion and analysis under the cover of the Form 40-F. In future filings, please provide the audited financial statements and accompanying management’s discussion and analysis in your Form 40-F rather than incorporating by reference these items into your Form 40-F. Alternatively, you may file these items as exhibits to the Form 40-F. Company Response: In future filings, we will provide the audited financial statements and accompanying management’s discussion and analysis in the Form 40-F or file these items as exhibits to the Form 40-F. In addition, as requested in your letter of December 9, 2011, we confirm that: · We are responsible for the adequacy and accuracy of the disclosure in our 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 · We 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. Yours truly, Progressive Waste Solutions Ltd. /s/ Thomas J. Cowee Thomas J. Cowee Vice President and Chief Financial Officer 2