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Section 1: LETTER

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Section 2: TEXT-EXTRACT

                                                           April 25, 2019

Gary Shedlin
Senior Managing Director & Chief Financial Officer
BlackRock, Inc.
55 East 52nd Street
New York, NY 10055

       Re: BlackRock, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Form 10-Q for the Quarterly Period Ended September 30, 2018
           Response dated December 28, 2018
           File No. 001-33099

Dear Mr. Shedlin:

       We have reviewed your December 28, 2018 response to our comment letter 
and have the
following comments. In some of our comments, we may ask you to provide us with 
information
so we may better understand your disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your 
response.

       After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to 
comments in
our December 17, 2018 letter.

Form 10-K for the Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of 
Operations
Non-GAAP Financial Measures, page 36

1.    We have reviewed your response to our comment letter and noted that you 
continue
      to disclose a non-GAAP adjustment to deduct distribution and servicing 
costs to arrive at
      an adjusted measure of revenue used for operating margin measurement. 
Based on the
      information provided, we believe your adjustment for distribution and 
servicing costs in
      the computation of "revenue used for operating margin measurement" 
substitutes an
      individually tailored recognition and measurement method for those of 
GAAP, which
      could violate Rule 100(b) of Regulation G. Accordingly, please do not 
disclose this
      adjustment in future filings. Refer to Question 100.04 of the Compliance 
and Disclosure
 Gary Shedlin
BlackRock, Inc.
April 25, 2019
Page 2
         Interpretations on Non-GAAP Financial Measures for guidance.
      You may contact Robert Klein, Staff Accountant, at (202) 551-3847 or Hugh 
West,
Accounting Branch Chief, at (202) 551-3872 with any questions.



FirstName LastNameGary Shedlin                            Sincerely,
Comapany NameBlackRock, Inc.
                                                          Division of 
Corporation Finance
April 25, 2019 Page 2                                     Office of Financial 
Services
FirstName LastName

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