SEC Comment Letter 0000000000-25-002541 to Booz Allen Hamilton Holding Corp (BAH)
Booz Allen Hamilton Holding Corp
Date: March 7, 2025 · CIK: 0001443646 · Accession: 0000000000-25-002541
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File numbers found in text: 001-34972
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March 7, 2025
Matthew Calderone
Executive Vice President and Chief Financial Officer
Booz Allen Hamilton Holding Corp
8283 Greensboro Drive
McLean, VA 22102
Re:Booz Allen Hamilton Holding Corp
Form 10-K for Fiscal Year Ended March 31, 2024
File No. 001-34972
Dear Matthew Calderone:
We have reviewed your filing and have the following comment(s).
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 March 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Measures, page 51
1.Please disclose how management uses the free cash flow conversion measure and why
you believe it provides useful information to investors. In addition, to the extent its
most comparable GAAP measure is not commonly used, describe what it represents
and how it is calculated. Refer to Item 10(e)(1)(i)(C) and (D) of Regulation S-K.
March 7, 2025
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.
Please contact Keira Nakada at 202-551-3659 or Angela Lumley at 202-551-3398 if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services