SEC Comment Letter for HERC HOLDINGS INC (HRI) (CIK 0001364479) (HRI) — May 16, 2017
HERC HOLDINGS INC (HRI) (CIK 0001364479)
Date: May 16, 2017 · CIK: 0001364479 · Accession: 0000000000-17-017140
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4631 DIVISION OF CORPORATION FINANCE Mail Stop 4631 May 15, 2017 Via E-mail Ms. Barbara L. Brasier Chief Financial Officer Herc Holdings Inc. 27500 Riverview Center Blvd. Bonita Springs, FL 34134
Re: Herc Holdings Inc. Form 10-K for Fiscal Year Ended December 31, 2016 Filed March 15, 2017 File No. 1-33139
Dear Ms. Brasier :
We have reviewed your filing an d 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 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 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 -K for Fiscal Year Ended December 31, 2016
Financial Statements
Note 21 – Segment Information, page 99
1. We note from your disclosures, you offer a variety of services and products in addition to having operations in various key markets. Please tell us what consideration you have given toward providing product line revenue disclosures in accordance with ASC 280 -10- 50-40.
Ms. Barbara L. Brasier Herc Holdings Inc. May 15, 2017 Page 2
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 Kevin Stertzel at (202) 551 -3723 , if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3768 with any other questions.
Sincerely,
/s/ W. John Cash
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4631 DIVISION OF CORPORATION FINANCE Mail Stop 4631 May 15, 2017 Via E-mail Ms. Barbara L. Brasier Chief Financial Officer Herc Holdings Inc. 27500 Riverview Center Blvd. Bonita Springs, FL 34134 Re: Herc Holdings Inc. Form 10-K for Fiscal Year Ended December 31, 2016 Filed March 15, 2017 File No. 1-33139 Dear Ms. Brasier : We have reviewed your filing an d 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 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 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 -K for Fiscal Year Ended December 31, 2016 Financial Statements Note 21 – Segment Information, page 99 1. We note from your disclosures, you offer a variety of services and products in addition to having operations in various key markets. Please tell us what consideration you have given toward providing product line revenue disclosures in accordance with ASC 280 -10- 50-40. Ms. Barbara L. Brasier Herc Holdings Inc. May 15, 2017 Page 2 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 Kevin Stertzel at (202) 551 -3723 , if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3768 with any other questions. Sincerely, /s/ W. John Cash W. John Cash Branch Chief Office of Manufacturing and Construction