0001193125-18-352089.txt : 20190215 0001193125-18-352089.hdr.sgml : 20190215 20181218161405 ACCESSION NUMBER: 0001193125-18-352089 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20181218 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CBIZ, Inc. CENTRAL INDEX KEY: 0000944148 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-BUSINESS SERVICES, NEC [7389] IRS NUMBER: 222769024 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6050 OAK TREE BOULEVARD, SOUTH STREET 2: SUITE 500 CITY: CLEVELAND STATE: OH ZIP: 44131 BUSINESS PHONE: 2164479000 MAIL ADDRESS: STREET 1: 6050 OAK TREE BOULEVARD, SOUTH STREET 2: SUITE 500 CITY: CLEVELAND STATE: OH ZIP: 44131 FORMER COMPANY: FORMER CONFORMED NAME: CENTURY BUSINESS SERVICES INC DATE OF NAME CHANGE: 19980218 FORMER COMPANY: FORMER CONFORMED NAME: INTERNATIONAL ALLIANCE SERVICES INC DATE OF NAME CHANGE: 19961031 CORRESP 1 filename1.htm Correspondence

CBIZ, INC.

6050 Oak Tree Boulevard, South

Suite 500

Cleveland, Ohio 44131

December 18, 2018

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3561

100 F. Street, N.E.

Washington, D.C. 20549

 

Attn:

Diane Fritz, Staff Accountant

    

Christine Dietz, Assistant Chief Accountant

 

Re:

CBIZ, Inc.

    

Form 10-K for the Fiscal Year Ended December 31, 2017

    

Filed March 1, 2018

    

Form 10-Q for the Quarterly Period Ended September 30, 2018

    

Filed November 1, 2018

    

File No. 001-32961

Ladies and Gentlemen:

Set forth below are the responses of CBIZ, Inc., a Delaware corporation (the “Company”), to the comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in a letter dated December 10, 2018 with respect to the Form 10-K submitted to the Staff on March 1, 2018 and the Form 10-Q submitted to the Staff on November 1, 2018 (collectively, the “Periodic Reports”).

For your convenience, the Company has set forth below each Staff comment followed by the Company’s response. Capitalized terms used but not otherwise defined in this letter have the meanings ascribed to such terms in the Periodic Reports.

Form 10-Q for the Quarterly Period Ended September 30, 2018

Notes to the Condensed Consolidated Financial Statements

Note 3. Revenue, page 12

 

1.

We note from your response to prior comment 1 that you do not consider your Benefit and Insurance Services practice group’s commissions to be incremental costs of obtaining a contract. Please tell us how you arrived at this conclusion. Refer to ASC 340-40-25-2. In addition, tell us the total amount of commissions expense recorded for contracts with terms in excess of one year during the nine months ended September 30, 2018.

United States Securities and Exchange Commission

December 18, 2018

Page 2

 

Response 1a: The Company acknowledges the Staff’s comments. ASC 340-40-25-2 states that the incremental costs of obtaining a contract are those that an entity incurs to obtain a contract with a customer that it would not have incurred if the contract had not been obtained (for example, a sales commission), but as discussed in the FASB Transition Resource Group memo number 57-16, there could be other fact patterns that need to be considered within different commission plans that affect the determination of whether the costs are incremental to obtaining the contract.

 

  •  

As noted in our previous response, the Company pays commissions monthly over the term of the underlying contract and requires the recipient of the commission to be employed by the Company at the time of payment (i.e. service vesting condition). Failure to remain employed at the date the commission is payable results in the forfeiture of commissions that would otherwise be due. Therefore, the Company has determined that the requirement of continued employment is substantive and accordingly does not consider such commissions to be incremental costs of obtaining the contract. As a result, a contract acquisition asset is not recognized for such commissions.

Response 1b: As noted in our previous response, the majority of the Company’s contracts have an original specified duration of one year or less. Certain contracts related to the Company’s group health and benefits consulting and property and casualty insurance businesses have an original specified contract duration in excess of one year.

The total amount of commissions expense recorded for contracts with terms in excess of one year during the nine months ended September 30, 2018 was approximately two hundred sixty thousand dollars.

 

2.

We note your response to prior comment 5. Please revise in future filings to disclose that advisory services revenue is calculated on the estimated value of assets under management and is adjusted when the actual value is provided.

Response 2: The Company acknowledges the Staff’s comment. The Company will enhance the footnote disclosure related to advisory services revenue in future filings.

*        *        *         *        *

If you have any questions with respect to the foregoing, please do not hesitate to call me at (216) 447-9000.

 

Sincerely,
/s/ Ware H. Grove

Ware H. Grove

Senior Vice President and Chief Financial Officer

 

cc:

Diane Fritz, Division of Corporation Finance