SEC Comment Letter 0000000000-24-004278 to Everus Construction Group, Inc. (ECG) (CIK 0002015845) (ECG)
Everus Construction Group, Inc. (ECG) (CIK 0002015845)
Date: April 18, 2024 · CIK: 0002015845 · Accession: 0000000000-24-004278
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United States securities and exchange commission logo
April 18, 2024
Jeffrey Thiede
President and Chief Executive Officer
Everus Construction Group, Inc.
1250 West Century Avenue
Bismarck, ND 58503
Re:Everus Construction Group, Inc.
Draft Registration Statement on Form 10-12B
Submitted March 22, 2024
CIK No. 0002015845
Dear Jeffrey Thiede:
We have reviewed your draft registration statement and have the following comments.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Exhibit 99.1 to Draft Registration Statement on Form 10-12B submitted March 22, 2024
Our Competitive Strengths
Broad geographic reach with local service delivery throughout the United States, page 10
1.We note your disclosure that you are authorized to work in nearly every state and the
District of Columbia and your map on page 69 indicating the locations where you have
work authorizations. Please consider including this map in the summary or revising to
disclose the specific number of authorizations you currently hold.
Diverse and attractive revenue base, page 11
2.We note the statement that your projects are supported by your "best-in-class" risk
management and project oversight framework. Please revise to provide the support for this
claim.
FirstName LastNameJeffrey Thiede
Comapany NameEverus Construction Group, Inc.
April 18, 2024 Page 2
FirstName LastName
Jeffrey Thiede
Everus Construction Group, Inc.
April 18, 2024
Page 2
Business
Our Company, page 58
3.We note that you currently deliver services through 15 Operating Companies. Please
identify any material Operating Companies and describe the nature of their services. For
each material Operating Company, please disclose the proportion of your ownership
interest.
Please contact Peter McPhun at 202-551-3581 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Kibum Park at 202-551-6836 or Isabel Rivera at 202-551-3518 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: John L. Robinson, Esq.