SEC Comment Letter for Otis Worldwide Corp (OTIS) (CIK 0001781335) (OTIS) — Jul 11, 2022
Otis Worldwide Corp (OTIS) (CIK 0001781335)
Date: July 11, 2022 · CIK: 0001781335 · Accession: 0000000000-22-007291
AI Filing Summary & Sentiment
File numbers found in text: 001-39221
Letter
United States securities and exchange commission logo July 11, 2022 Rahul Ghai Chief Financial Officer Otis Worldwide Corp One Carrier Place Farmington, Connecticut 06032 Re:Otis Worldwide Corp Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 4, 2022 Form 10-Q for the Quarterly Period Ended March 31, 2022 Filed April 27, 2022 File No. 001-39221 Dear Mr. Ghai: We have reviewed your July 1, 2022 response to our comment letter and have the following comment. Please respond to this 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 apply 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 reference to the prior comment are to comment in our June 6, 2022 letter. Form 10-Q for the quarterly period ended March 31, 2022 Risk Factors, page 41 1.We note your response to prior comment 3 that you disclose in your 2022 Proxy Statement the extensive role of your Board of Directors and its Committees in overseeing risks at Otis, and that the Board of Directors and its Committees regularly review and receive reports on the risks impacting the Company. Please include specific disclosure in your periodic filings regarding Board of Director oversight of the risks associated with the crisis in Ukraine. Also, in regards to your statement that you will continue to fulfill your existing agreements and provide essential equipment and services in Russia, please quantify the estimated amounts that the company may be required to pay. Additionally, to the extent there were material changes to the risks since the filing of your Form 10-Q for
FirstName LastNameRahul Ghai Comapany NameOtis Worldwide Corp July 11, 2022 Page 2 FirstName LastName Rahul Ghai Otis Worldwide Corp July 11, 2022 Page 2 the quarterly period ended March 31, 2022, please provide us with the disclosures you intend to include in your future filings. You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Claire Erlanger, Senior Staff Accountant, at 202-551-3301 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
July 11, 2022
Rahul Ghai
Chief Financial Officer
Otis Worldwide Corp
One Carrier Place
Farmington, Connecticut 06032
Re:Otis Worldwide Corp
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 4, 2022
Form 10-Q for the Quarterly Period Ended March 31, 2022
Filed April 27, 2022
File No. 001-39221
Dear Mr. Ghai:
We have reviewed your July 1, 2022 response to our comment letter and have the
following comment.
Please respond to this 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 apply 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 reference to the prior comment are to comment in our
June 6, 2022 letter.
Form 10-Q for the quarterly period ended March 31, 2022
Risk Factors, page 41
1.We note your response to prior comment 3 that you disclose in your 2022 Proxy
Statement the extensive role of your Board of Directors and its Committees in overseeing
risks at Otis, and that the Board of Directors and its Committees regularly review and
receive reports on the risks impacting the Company. Please include specific disclosure in
your periodic filings regarding Board of Director oversight of the risks associated with the
crisis in Ukraine. Also, in regards to your statement that you will continue to fulfill your
existing agreements and provide essential equipment and services in Russia, please
quantify the estimated amounts that the company may be required to pay. Additionally, to
the extent there were material changes to the risks since the filing of your Form 10-Q for
FirstName LastNameRahul Ghai
Comapany NameOtis Worldwide Corp
July 11, 2022 Page 2
FirstName LastName
Rahul Ghai
Otis Worldwide Corp
July 11, 2022
Page 2
the quarterly period ended March 31, 2022, please provide us with the disclosures you
intend to include in your future filings.
You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Claire
Erlanger, Senior Staff Accountant, at 202-551-3301 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing