Re:
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Automatic Data Processing, Inc.
Definitive Additional Materials on Schedule 14A
Filed October 17 and 19, 2017
File No. 001-05397
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1. | We note your response to prior comment 3 and your subsequent soliciting materials that reference expected operational margin expansion of 500 basis points over the next three years. Please clarify how operational margins differ from net operational margins and provide the reconciliation required by Regulation G and Item 10(e) of Regulation S-K in the next filing you make in connection with this solicitation. |
$M
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2017
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||||
Net earnings from continuing operations
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1,733.4
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||||
Adjustments
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|||||
Provision for income taxes
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797.7
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||||
All other interest expense
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59.3
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||||
All other interest income
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(22.4
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)
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|||
Gain on sale of businesses
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(205.4
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)
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|||
Workforce Optimization Effort
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(5.0
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)
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|||
Service Alignment Initiative
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90.0
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||||
Adjusted EBIT
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2,447.6
|
||||
Revenues
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12,379.8
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||||
Adjusted EBIT margin %
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19.8
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%
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|||
PEO passthrough costs (A)
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2,628.4
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||||
PEO passthrough costs/total revenues
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21.2
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%
|
|||
Client funds interest revenue (A)
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397.4
|
||||
Corporate extended interest income (B)
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54.3
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||||
Corporate extended interest expense (C)
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(20.7
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)
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|||
Net client funds strategy
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431.0
|
||||
Net client funds strategy/total revenues
|
3.5
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%
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Non-GAAP reconciliations of various inputs in
calculation above
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|||||
(A) Composition of Revenue
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|||||
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2017
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||||
PEO passthrough revenues
|
2,628.4
|
||||
Client funds interest revenue
|
397.4
|
||||
Other revenues
|
9,354.0
|
||||
Revenues from continuing operations
|
12,379.8
|
||||
|
|||||
(A) Composition of Operating Expenses
|
2017
|
||||
PEO passthrough costs
|
2,628.4
|
||||
Other Operating Expenses
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3,787.7
|
||||
Operating Expenses
|
6,416.1
|
||||
|
|||||
(B) Composition of Other income, net
|
2017
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||||
Corporate extended interest income
|
54.3
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||||
Other interest income
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22.4
|
||||
Other Other income, net
|
207.6
|
||||
Other income, net
|
284.3
|
||||
|
|||||
(C) Composition of Interest Expense
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2017
|
||||
Corporate extended interest expense
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20.7
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||||
Other interest expense
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59.3
|
||||
Interest Expense
|
80.0
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