Ceridian HCM Holding Inc.
3311 East Old Shakopee Road
Minneapolis, Minnesota 55425
March 15, 2019
VIA EDGAR AND EMAIL
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, D.C. 20549-3561
Attn: Mitchell Austin
| Re: | Ceridian HCM Holding Inc. |
Registration Statement on Form S-1 Filed on March 15, 2019 |
Ladies and Gentlemen:
We refer to the registration statement on Form S-1 filed on March 15, 2019 (as amended, the “Registration Statement”), of Ceridian HCM Holding Inc. (the “Company”), relating to the registration of the Company’s common stock, par value $0.01 per share.
In accordance with Rules 460 and 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby respectfully requests that the effectiveness of the Registration Statement be accelerated so that it may become effective at 4:30 P.M. (Eastern time) on Tuesday, March 19, 2019, or as soon as practicable thereafter.
The Company hereby acknowledges the following:
| • | should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
In addition, the Company hereby confirms that it is aware of its responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement.
Please call Alexander D. Lynch at (212) 310-8971 or Ashley Butler at (212) 310-8855, of Weil, Gotshal & Manges LLP, to confirm the effectiveness of the Registration Statement.
Very truly yours,
Ceridian HCM Holding Inc. | ||
| By: | /s/ Scott. A. Kitching | |
Name: Scott A. Kitching Title: Executive Vice President, General Counsel and Assistant Secretary | ||
