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United States securities and exchange commission logo
May 9, 2024
W. Troy Rudd
Chief Executive Officer
AECOM
13355 Noel Road
Dallas, TX 75240
Re: AECOM
Form 10-K for
Fiscal Year Ended September 20, 2023
File No. 000-52423
Dear W. Troy Rudd:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
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 September 30, 2023
Notes to Consolidated Financial Statements
Note 4. Revenue Recognition, page 68
1. We note your discussion
of customer end markets on page 5 and the quantification of
changes in revenue for
end markets in the proposed, revised results of operations
disclosure in your
response. Please tell us what consideration you have given to providing
additional revenue
disaggregation on the basis of major customer end markets, which
would provide context
to the changes in revenue for end markets disclosed in your results
of operations
disclosure.
Note 16. Other Financial Information, page 88
2. We note your response
to prior comment 3 stating that you investigate any change in gross
profit percentage
related to changes in estimates that result in an increase or decrease in
revenue of greater than
$1 million for the period at an individual contract level. Please tell
us the aggregate impact
of all changes in contract estimates on your results of operations
(revenue and income
from operations) for each year of the three year period ended
W. Troy Rudd
AECOM
May 9, 2024
Page 2
September 30, 2023 (absent a threshold). If you do not track and/or
assess all changes in
contract estimates, tell us how you determined the aggregate impact of
all changes in
contract estimates did not have a material impact to the financial
statements. Please also
clarify whether the impact quantified in your response of 0.1% was
measured using
quarterly or annual amounts.
Note 19. Reportable Segments and Geographic Information, page 91
3. We note your response to prior comment 4 and your proposed, revised
disclosure on page
15. Please revise your disclosure to explain in more detail the
factors used to identify your
reportable segments. It appears that a summarized version of the
information provided on
pages 8 and 9 of your response, where you describe the operating
segments aggregated
into reporting segments and your consideration of additional
information reported to the
CODM on a global end market basis, would meet the objectives of ASC
280-10- 50-21
and allow investors to understand how you determined your reportable
segments.
In closing, 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 Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380
with any
questions.
FirstName LastNameW. Troy Rudd Sincerely,
Comapany NameAECOM
Division of
Corporation Finance
May 9, 2024 Page 2 Office of Trade
& Services
FirstName LastName