SEC Comment Letter for Booz Allen Hamilton Holding Corp (BAH) (CIK 0001443646) (BAH) — Jul 9, 2012
Booz Allen Hamilton Holding Corp (BAH) (CIK 0001443646)
Date: July 9, 2012 · CIK: 0001443646 · Accession: 0000000000-12-035673
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34972
Letter
July 9, 2012 Via E -mail Mr. Samuel R. Strickland Chief Financial Officer Booz Allen Hamilton Holding Corporation 8283 Greensboro Drive McLean, VA 22102
Re: Booz Allen Hamilton Holding Corporation Form 10-K Filed May 30, 2012 File No. 001-34972
Dear Mr. Strickland :
We have reviewed your filing an d 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstanc es or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comments.
Form 10 -K for the year ended March 31, 2012
Exhibit 31
1. We note that the fourth paragraph of the Section 302 certification does not refer to the certifying officers’ responsibility for establishing and maintaining effective internal control over financial reporting. Please amend your filing to provide a certification that includes the exact wording prescribed by Item 601(b)(31) of Regulation S -K.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that t he 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, they are responsible for the accu racy and adequacy of the disclosures they have made.
Samuel R. Strickland Booz Allen Hamilton Holding Corporation July 9, 2012 Page 2
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the 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
the company may not assert staff comments as a defense in any proceeding initiated by the Commission o r any person under the federal securities laws of the United States.
You may contact Kristi Marrone at (202) 551 -3429 me at (202) 551 -3486 with any questions.
Sincerely,
/s/ Daniel L. Gordon
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July 9, 2012 Via E -mail Mr. Samuel R. Strickland Chief Financial Officer Booz Allen Hamilton Holding Corporation 8283 Greensboro Drive McLean, VA 22102 Re: Booz Allen Hamilton Holding Corporation Form 10-K Filed May 30, 2012 File No. 001-34972 Dear Mr. Strickland : We have reviewed your filing an d 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 letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstanc es or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comments. Form 10 -K for the year ended March 31, 2012 Exhibit 31 1. We note that the fourth paragraph of the Section 302 certification does not refer to the certifying officers’ responsibility for establishing and maintaining effective internal control over financial reporting. Please amend your filing to provide a certification that includes the exact wording prescribed by Item 601(b)(31) of Regulation S -K. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that t he 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, they are responsible for the accu racy and adequacy of the disclosures they have made. Samuel R. Strickland Booz Allen Hamilton Holding Corporation July 9, 2012 Page 2 In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the 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 the company may not assert staff comments as a defense in any proceeding initiated by the Commission o r any person under the federal securities laws of the United States. You may contact Kristi Marrone at (202) 551 -3429 me at (202) 551 -3486 with any questions. Sincerely, /s/ Daniel L. Gordon Daniel L. Gordon Branch Chief