SEC Comment Letter for Booz Allen Hamilton Holding Corp (BAH) (CIK 0001443646) (BAH) — Sep 15, 2017
Booz Allen Hamilton Holding Corp (BAH) (CIK 0001443646)
Date: Sept. 15, 2017 · CIK: 0001443646 · Accession: 0000000000-17-032842
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3233 September 15, 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 August 31, 2017 response to our comment letter 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 applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 17, 2017 letter .
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Contract Backlog, page 49 1. We have reviewed your response to comme nt 1. Please provide us a detailed description of your estimation process for determining the amount of, and recording periodic changes to, funded backlog as disclosed within your filing. In your response, describe the significant assumptions used to ass ess management’s ability to fulfill the services that are to be provided under existing funded contracts, how these assumptions impact the estimate, how management assesses the reasonableness of the assumptions, and how management assesses the accuracy of the estimate. Lastly, ensure your description of the
Lloyd W. Howell, Jr. Booz Allen Hamilton Holding Corporation September 15, 2017 Page 2
process addresses the various contingencies you mentioned in your response and their effect o n the estimation process.
You may contact Mark Rakip, Staff Accountant, at 202.551.3573 or me at 202.551.342 9 if you have questions regarding the comment on the financial statements and related matters.
Sincerely,
/s/ Kristi Marrone
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Mailstop 3233 September 15, 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 August 31, 2017 response to our comment letter 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 applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 17, 2017 letter . Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Contract Backlog, page 49 1. We have reviewed your response to comme nt 1. Please provide us a detailed description of your estimation process for determining the amount of, and recording periodic changes to, funded backlog as disclosed within your filing. In your response, describe the significant assumptions used to ass ess management’s ability to fulfill the services that are to be provided under existing funded contracts, how these assumptions impact the estimate, how management assesses the reasonableness of the assumptions, and how management assesses the accuracy of the estimate. Lastly, ensure your description of the Lloyd W. Howell, Jr. Booz Allen Hamilton Holding Corporation September 15, 2017 Page 2 process addresses the various contingencies you mentioned in your response and their effect o n the estimation process. You may contact Mark Rakip, Staff Accountant, at 202.551.3573 or me at 202.551.342 9 if you have questions regarding the comment on the financial statements and related matters. Sincerely, /s/ Kristi Marrone Kristi Marrone Staff Accountant Office of Real Estate and Commodities