SEC Comment Letter for Otis Worldwide Corp (OTIS) (CIK 0001781335) (OTIS) — Feb 21, 2020
Otis Worldwide Corp (OTIS) (CIK 0001781335)
Date: Feb. 21, 2020 · CIK: 0001781335 · Accession: 0000000000-20-001620
AI Filing Summary & Sentiment
File numbers found in text: 001-39221
Letter
February 21, 2020 Judith F. Marks President and Chief Executive Officer Otis Worldwide Corporation One Carrier Place Farmington, CT 06032 Re:Otis Worldwide Corporation Registration Statement on Form 10 Filed February 7, 2020 File No. 001-39221 Dear Ms. Marks: We have reviewed your filing and 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 business days by providing the requested information or advise 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 and any amendment you may file in response to these comments, we may have additional comments. Form 10 Registration Statement Unaudited Pro Forma Combined Financial Information Notes to the Unaudited Pro Forma Combined Financial Information, page 61 1.Refer to Note 2(F) on page 62. Given that you will incur a substantial amount of indebtedness in connection with the separation and distribution, please give consideration to including in a tabular format, the individual amounts pertaining to each debt category. In this regard, disclose the aggregated amount, range of interest rates and range of maturity dates of the unsubordinated debt, unsecured notes, and term loans.
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.
FirstName LastNameJudith F. Marks Comapany NameOtis Worldwide Corporation February 21, 2020 Page 2 FirstName LastName Judith F. Marks Otis Worldwide Corporation February 21, 2020 Page 2 You may contact Beverly Singleton at 202-551-3328 or Claire Erlanger at 202-551- 3301 if you have questions regarding comments on the financial statements and related matters. Please contact John Stickel at 202-551-3324 or John Dana Brown at 202-551-3859 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
Show Raw Text
February 21, 2020
Judith F. Marks
President and Chief Executive Officer
Otis Worldwide Corporation
One Carrier Place
Farmington, CT 06032
Re:Otis Worldwide Corporation
Registration Statement on Form 10
Filed February 7, 2020
File No. 001-39221
Dear Ms. Marks:
We have reviewed your filing and 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 business days by providing the requested
information or advise 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 and any amendment you may file in response to these
comments, we may have additional comments.
Form 10 Registration Statement
Unaudited Pro Forma Combined Financial Information
Notes to the Unaudited Pro Forma Combined Financial Information, page 61
1.Refer to Note 2(F) on page 62. Given that you will incur a substantial amount of
indebtedness in connection with the separation and distribution, please give consideration
to including in a tabular format, the individual amounts pertaining to each debt category.
In this regard, disclose the aggregated amount, range of interest rates and range of
maturity dates of the unsubordinated debt, unsecured notes, and term loans.
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.
FirstName LastNameJudith F. Marks
Comapany NameOtis Worldwide Corporation
February 21, 2020 Page 2
FirstName LastName
Judith F. Marks
Otis Worldwide Corporation
February 21, 2020
Page 2
You may contact Beverly Singleton at 202-551-3328 or Claire Erlanger at 202-551-
3301 if you have questions regarding comments on the financial statements and related
matters. Please contact John Stickel at 202-551-3324 or John Dana Brown at 202-551-3859 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance