UPLOAD: SEC-generated letter
Published on April 22, 2005
Mail Stop 0407
April 22, 2005
Via U.S. Mail and Fax (503) 220-0987
Mr. Michael D. Mulholland
Vice President - Finance and Secretary
Barrett Business Services, Inc.
4724 SW Macadam Avenue
Portland, Oregon 97239
RE: Barrett Business Services, Inc..
Form 10-K for the fiscal year ended December 31, 2004
Filed March 30, 2005
File No. 33-61804
Dear Mr. Mulholland:
We have reviewed the above referenced filing and have the
following comments. We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents. As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934. Please address the following
comments in future filings. If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a future
revision is unnecessary. Please be as detailed as necessary in
your
explanation. In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure. After reviewing this information, we may or may not
raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Item 1. Business
Workers` Compensation Claims Experience and Reserves, page 8.
1. Tell us in more detail how you measure "future adverse loss
development in excess of initial case reserves"
Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations
Overview, page 15.
2. Tell us your basis for netting safety incentive cost against
PEO
revenue.
Results of Operations, pages 18-20.
3. Tell us in more detail of the nature of your relationship with
your customers relating to PEO services. Also, tell us why you
are
considered a co employer under your contracts for these services.
4. Tell us why your "net" presentation of PEO service fees
appears
to exclude payroll taxes and benefits related to PEO staff.
Additionally, tell us in detail why you allocated most of the
workers` compensation costs to the staffing service business,
despite
the fact that most of the revenue growth was generated by the PEO
business.
Notes to Consolidated Financial Statements.
1. Summary of Operations and Significant Accounting Policies.
Nature of Operations, page F-6.
5. Addressing SFAS 131, tell us how you concluded that you only
have
one reportable segment. If you aggregated operating segments under
paragraph 17 of SFAS 131, tell us your basis for aggregation.
Revision in classification, page F-10.
6. Tell us the nature and magnitude of workers` compensation
liabilities that are in excess of the deductible limits of
insurance
coverage. What circumstances caused you to exceed the insurance
limits?
7. Workers` Compensation Claims, page F-15.
7. Tell us when the CNA insurance receivable is collectible.
Please
describe the nature of the insurance arrangement, why it is
classified as long-term in the financial statements, and whether
you
considered a valuation allowance as of the balance sheet date.
Additionally, we note that you referred to CNA Financial
Corporation
as your prior excess workers` compensation insurer. Tell us who
your
current insurer is and why your CNA insurance receivable was not
settled prior to any change in insurers.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information. Please file your response
letter
on EDGAR.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.
You may contact Kathryn Jacobson, Staff Accountant, at (202)
551-3365 or Carlos Pacho, Senior Assistant Chief Accountant, at
(202) 551-3835 you have questions regarding comments on the
financial
statements and related matters. Please contact me at (202) 551-
3810
with any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Michael D. Mulholland
Barrett Business Services, Inc.
April 22, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE