SEC Comment Letter 0000000000-24-003221 to BROADRIDGE FINANCIAL SOLUTIONS, INC. (BR) (CIK 0001383312) (BR)
BROADRIDGE FINANCIAL SOLUTIONS, INC. (BR) (CIK 0001383312)
Date: March 25, 2024 · CIK: 0001383312 · Accession: 0000000000-24-003221
AI Filing Summary & Sentiment
File numbers found in text: 001-33220
Letter
United States securities and exchange commission logo March 25, 2024 Edmund L. Reese Corporate Vice President and Chief Financial Officer Broadridge Financial Solutions, Inc. 5 Dakota Drive Lake Success, NY 11042 Re:Broadridge Financial Solutions, Inc. Form 10-K for Fiscal Year Ended June 30, 2023 File No. 001-33220 Dear Edmund L. Reese: We have limited our review of your filing to the financial statements and related disclosures 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended June 30, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Financial Condition, Liquidity and Capital Resources Cash Flows, page 45 1.You report you paid $54.3 million and $102.8 million more in interest and income taxes, respectfully, for fiscal 2023 than in fiscal 2022. However, you did not cite these as contributing factors in your analysis of changes in the reported amount of net operating cash flows. It appears these factors would materially affect your analysis. Please disclose all material factors affecting the reported amount of net operating cash flows between periods, including where material changes offset one another. Refer to Item 303 of Regulation S-K. Also refer to the introductory paragraph of section IV.B and all of section B.1 of Release No. 33-8350 for guidance regarding the analysis of operating cash flows. Further, quantify variance factors cited in all annual and interim period reports pursuant to section III.D of Release No. 33-6835.
FirstName LastNameEdmund L. Reese Comapany NameBroadridge Financial Solutions, Inc. March 25, 2024 Page 2 FirstName LastName Edmund L. Reese Broadridge Financial Solutions, Inc. March 25, 2024 Page 2
In closing, 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. Please contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 25, 2024
Edmund L. Reese
Corporate Vice President and Chief Financial Officer
Broadridge Financial Solutions, Inc.
5 Dakota Drive
Lake Success, NY 11042
Re:Broadridge Financial Solutions, Inc.
Form 10-K for Fiscal Year Ended June 30, 2023
File No. 001-33220
Dear Edmund L. Reese:
We have limited our review of your filing to the financial statements and related
disclosures 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended June 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Financial Condition, Liquidity and Capital Resources
Cash Flows, page 45
1.You report you paid $54.3 million and $102.8 million more in interest and income taxes,
respectfully, for fiscal 2023 than in fiscal 2022. However, you did not cite these as
contributing factors in your analysis of changes in the reported amount of net operating
cash flows. It appears these factors would materially affect your analysis. Please disclose
all material factors affecting the reported amount of net operating cash flows between
periods, including where material changes offset one another. Refer to Item 303 of
Regulation S-K. Also refer to the introductory paragraph of section IV.B and all of section
B.1 of Release No. 33-8350 for guidance regarding the analysis of operating cash
flows. Further, quantify variance factors cited in all annual and interim
period reports pursuant to section III.D of Release No. 33-6835.
FirstName LastNameEdmund L. Reese
Comapany NameBroadridge Financial Solutions, Inc.
March 25, 2024 Page 2
FirstName LastName
Edmund L. Reese
Broadridge Financial Solutions, Inc.
March 25, 2024
Page 2
In closing, 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.
Please contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services