0000077543-17-000063.txt : 20170920 0000077543-17-000063.hdr.sgml : 20170920 20170804210017 ACCESSION NUMBER: 0000077543-17-000063 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20170804 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TUTOR PERINI CORP CENTRAL INDEX KEY: 0000077543 STANDARD INDUSTRIAL CLASSIFICATION: GENERAL BUILDING CONTRACTORS - NONRESIDENTIAL BUILDINGS [1540] IRS NUMBER: 041717070 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 15901 OLDEN STREET CITY: SYLMAR STATE: CA ZIP: 91342 BUSINESS PHONE: 818-362-8391 MAIL ADDRESS: STREET 1: 15901 OLDEN STREET CITY: SYLMAR STATE: CA ZIP: 91342 FORMER COMPANY: FORMER CONFORMED NAME: TUTOR PERINI Corp DATE OF NAME CHANGE: 20090529 FORMER COMPANY: FORMER CONFORMED NAME: PERINI CORP DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm CORRESP - Response Letter 2

Tutor Perini Corporation

15901 Olden Street

Sylmar, CA 91342

Tel: 818/362-8391 Fax: 818/367-5379

August 4, 2017



VIA EDGAR



Mr. John Cash

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street,  N.E.

Washington, DC 20549





 

Re:

Tutor Perini Corporation



Form 10-K for the Year Ended December 31, 2016



Filed February 23, 2017



Definitive Proxy Statement Filed April 13, 2017



File No. 001-06314





Dear Mr. Cash:



Set forth below is the response of Tutor Perini Corporation (the “Company”) to the letter dated August 4, 2017 providing further comment of the staff (the “Staff”) of the Securities and Exchange Commission on the Company’s Definitive Proxy Statement filed on April 13, 2017. 



For ease of reference, the Staff’s comment is reproduced below in bold font and followed by the Company’s response thereto.





Definitive Proxy Statement filed April 13, 2017



Compensation Discussion and Analysis, page 26



General



1.  Your response to comment 3 of our letter dated July 6, 2017 appears to be inconsistent with your disclosure on page 31 of your proxy statement. In future filings, please clarify that you intend to pay the remaining $1.25 million of $5 million succession planning bonus.



Response:



In future filings, the Company will clarify that it intends to pay the remaining $1.25 million of Mr. Tutor’s $5 million succession planning bonus when earned, unless the remaining payment has already been made prior to such filing, in which case the Company will disclose the payment and the basis for the payment.







Please feel free to contact me at 818/362-8391 if you have any questions.





Sincerely,







/s/ Gary G. Smalley

Gary G.  Smalley

Executive Vice President and Chief Financial Officer