SEC Comment Letter for HERC HOLDINGS INC (HRI) (CIK 0001364479) (HRI) — May 11, 2016
HERC HOLDINGS INC (HRI) (CIK 0001364479)
Date: May 11, 2016 · CIK: 0001364479 · Accession: 0000000000-16-075953
AI Filing Summary & Sentiment
Letter
May 11, 2016 Thomas C. Kennedy Senior Executive Vice President and Chief Financial Officer Hertz Global Holdings, Inc. 8501 Williams Road Estero, FL 33928
Re: Hertz Global Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2015 Filed February 29, 2016 File No. 01 -33139
Dear Mr. Kennedy :
We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts a nd circumstances , please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2015
Item 1. Business, page 6
1. We note you generate revenue from car rentals and franchise fees. Please tell us what consideration you gave to the financial statement disclosures required by ASC 952 -605- 45 and 50.
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, the y are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comment , please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the di sclosure in the filing;
Thomas C. Kennedy Hertz Global Holdings, Inc. May 11, 2016 Page 2
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 Theresa Messinese at 202-551-3307 or me at 202-551-3380 if you have questions regarding comments on the financial statements and rel ated matt ers.
Sincerely,
/s/ Lyn Shenk
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May 11, 2016 Thomas C. Kennedy Senior Executive Vice President and Chief Financial Officer Hertz Global Holdings, Inc. 8501 Williams Road Estero, FL 33928 Re: Hertz Global Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2015 Filed February 29, 2016 File No. 01 -33139 Dear Mr. Kennedy : We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts a nd circumstances , please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2015 Item 1. Business, page 6 1. We note you generate revenue from car rentals and franchise fees. Please tell us what consideration you gave to the financial statement disclosures required by ASC 952 -605- 45 and 50. 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, the y are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment , please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the di sclosure in the filing; Thomas C. Kennedy Hertz Global Holdings, Inc. May 11, 2016 Page 2 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 Theresa Messinese at 202-551-3307 or me at 202-551-3380 if you have questions regarding comments on the financial statements and rel ated matt ers. Sincerely, /s/ Lyn Shenk Lyn Shenk Branch Chief Office of Transportation and Leisure