SEC Comment Letter for Booz Allen Hamilton Holding Corp (BAH) (CIK 0001443646) (BAH) — Aug 17, 2017
Booz Allen Hamilton Holding Corp (BAH) (CIK 0001443646)
Date: Aug. 17, 2017 · CIK: 0001443646 · Accession: 0000000000-17-029229
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3233 August 17, 2017 Via E -Mail Lloyd W. Howell, Jr. Executive Vice President, Chief Financial Officer and Treasurer Booz Allen Hamilton Holding Corpo ration 8283 Greensboro Drive McLean, VA 22102
Re: Booz Allen Hamilton Holding Corporation Form 10 -K for the fis cal year ended March 31, 2017 Filed May 22, 2017 File No. 1 -34972
Dear Mr. Howell :
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.
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Contract Backlog, page 49 1. We note you are unable to predict with any certainty the portion of backlog that you expect to recognize as revenue. Please expl ain why you are unable to estimate the amount of funded backlog as of March 31, 2017 that is expected to be converted into sales in fiscal 2018. In addition, consider disclosing how backlog impacts current period earnings , including the amount of current period revenues derived from t he backlog of prior period s, or tell us why you believe such disclosure is not beneficial to investors.
Lloyd W. Howell, Jr. Booz Allen Hamilton Holding Corporation August 17, 2017 Page 2
Note 2. Summary of Significant Accounting Policies, page F -8
Self-Funded Medical Plans, page F -12 2. In future periodic filings, please disclose a roll forward of your self -funded insurance reserves for each year presented. The roll forward should include the amount of incurred claims, any changes in the provision for prior year events, and the amount of payments made. Provide an example of your proposed disclosure. To the extent you do not believe this disclosure is material, tell us how you made that determination. Refer to ASC 944 - 40-50-3.
We remind you that the co mpany 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 Mark Rakip, Staff Accountant , at 202.551.3573 or me at 202.551.3429 if you have questions regarding comments on the financial statements and re lated matters.
Sincerely,
/s/ Kristi Marrone
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Mailstop 3233 August 17, 2017 Via E -Mail Lloyd W. Howell, Jr. Executive Vice President, Chief Financial Officer and Treasurer Booz Allen Hamilton Holding Corpo ration 8283 Greensboro Drive McLean, VA 22102 Re: Booz Allen Hamilton Holding Corporation Form 10 -K for the fis cal year ended March 31, 2017 Filed May 22, 2017 File No. 1 -34972 Dear Mr. Howell : 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. Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Contract Backlog, page 49 1. We note you are unable to predict with any certainty the portion of backlog that you expect to recognize as revenue. Please expl ain why you are unable to estimate the amount of funded backlog as of March 31, 2017 that is expected to be converted into sales in fiscal 2018. In addition, consider disclosing how backlog impacts current period earnings , including the amount of current period revenues derived from t he backlog of prior period s, or tell us why you believe such disclosure is not beneficial to investors. Lloyd W. Howell, Jr. Booz Allen Hamilton Holding Corporation August 17, 2017 Page 2 Note 2. Summary of Significant Accounting Policies, page F -8 Self-Funded Medical Plans, page F -12 2. In future periodic filings, please disclose a roll forward of your self -funded insurance reserves for each year presented. The roll forward should include the amount of incurred claims, any changes in the provision for prior year events, and the amount of payments made. Provide an example of your proposed disclosure. To the extent you do not believe this disclosure is material, tell us how you made that determination. Refer to ASC 944 - 40-50-3. We remind you that the co mpany 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 Mark Rakip, Staff Accountant , at 202.551.3573 or me at 202.551.3429 if you have questions regarding comments on the financial statements and re lated matters. Sincerely, /s/ Kristi Marrone Kristi Marrone Staff Accountant Office of Real Estate and Commodities