SEC Comment Letter 0000000000-23-001398 to Booz Allen Hamilton Holding Corp (BAH)
Booz Allen Hamilton Holding Corp
Date: Feb. 10, 2023 · CIK: 0001443646 · Accession: 0000000000-23-001398
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34972
Letter
United States securities and exchange commission logo February 10, 2023 Horacio Rozanski President and Chief Executive Officer Booz Allen Hamilton Holding Corp 8283 Greensboro Drive McLean, VA 22102 Re:Booz Allen Hamilton Holding Corp Form 10-K for the Fiscal Year Ended March 31, 2022 Filed May 20, 2022 File No. 001-34972 Dear Horacio Rozanski: We have reviewed your filing 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 the comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended March 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Measures, page 47 1.Your disclosure in footnote (a) indicates that your adjustments for acquisition and divestiture costs include compensation expenses associated with employee retention. Please tell us the periods over which these types of compensation costs are expected to be incurred. Please note that if these costs are expected to be incurred over periods in excess of one year, they may be considered normal recurring expenses associated with your business which should not be deducted in calculating your Non-GAAP measures. Refer to the guidance in Question 100.01 of the staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameHoracio Rozanski Comapany NameBooz Allen Hamilton Holding Corp February 10, 2023 Page 2 FirstName LastName Horacio Rozanski Booz Allen Hamilton Holding Corp February 10, 2023 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 Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
United States securities and exchange commission logo
February 10, 2023
Horacio Rozanski
President and Chief Executive Officer
Booz Allen Hamilton Holding Corp
8283 Greensboro Drive
McLean, VA 22102
Re:Booz Allen Hamilton Holding Corp
Form 10-K for the Fiscal Year Ended March 31, 2022
Filed May 20, 2022
File No. 001-34972
Dear Horacio Rozanski:
We have reviewed your filing 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 the comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures, page 47
1.Your disclosure in footnote (a) indicates that your adjustments for acquisition and
divestiture costs include compensation expenses associated with employee retention.
Please tell us the periods over which these types of compensation costs are expected to be
incurred. Please note that if these costs are expected to be incurred over periods in excess
of one year, they may be considered normal recurring expenses associated with your
business which should not be deducted in calculating your Non-GAAP measures. Refer
to the guidance in Question 100.01 of the staff's Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures.
FirstName LastNameHoracio Rozanski
Comapany NameBooz Allen Hamilton Holding Corp
February 10, 2023 Page 2
FirstName LastName
Horacio Rozanski
Booz Allen Hamilton Holding Corp
February 10, 2023
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 Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services