corresp
October 14, 2011
Via EDGAR and Overnight Delivery
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E., Mail Stop 3561
Washington, DC 20549
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Attention: |
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Mr. Patrick Kuhn, Staff Accountant |
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Re: |
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Visteon Corporation
Form 8-K
Filed October 4, 2011
File No. 001-15827 |
Dear Mr. Kuhn:
This letter is in response to your comment letter dated October 11, 2011 directed to Mr. Michael J.
Widgren, Vice President, Corporate Controller and Chief Accounting Officer of Visteon Corporation
(the Company). Your comment is reproduced below in bold italics, followed by the Companys
response.
1. We remind you that your Form 8-K will need to be amended within five business days of the
conclusion of your 2011 fiscal year audit and the filing of the related Form 10-K, which appears to
be the date of the intended dismissal of PricewaterhouseCoopers LLP, as stated in the Item 4.01
[of] Form 8-K filed on October 4, 2011. The amended Form 8-K should indicate whether there are any
disagreements between the Company and PricewaterhouseCoopers LLP through that date and include an
updated letter from PricewaterhouseCoopers LLP addressing your revised disclosure, filed as an
exhibit to your amended Form 8-K. Please affirm to us that you will amend your Form 8-K to provide
the updated disclosure within the five days of the conclusion of your 2011 fiscal year audit and
the filing of the related Form 10-K.
The Company affirms that it will amend its Form 8-K to provide the updated disclosure within the
five days of the conclusion of its 2011 fiscal year audit and the filing of its related Form 10-K,
which is the date of the Companys intended dismissal of PricewaterhouseCoopers LLP.
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We acknowledge the following:
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the Company is responsible for the adequacy and accuracy of the disclosure in
the filing; |
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staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and |
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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. |
If you have further questions regarding the matters discussed in this letter, you may contact Mr.
Michael J. Widgren at (734) 710-2227 or me at (734) 710-5266.
Very truly yours,
/s/ Peter M. Ziparo
Peter M. Ziparo
Assistant General Counsel
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cc: |
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Mr. William G. Quigley, III
Mr. Michael J. Widgren
Michael K. Sharnas, Esq. |
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