SEC Comment Letter for NCR Voyix Corp (VYX, NCRRP) (CIK 0000070866) (VYX) — Nov 2, 2017
NCR Voyix Corp (VYX, NCRRP) (CIK 0000070866)
Date: Nov. 2, 2017 · CIK: 0000070866 · Accession: 0000000000-17-038866
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Letter
Mail Stop 4561 November 2, 2017 Robert Fishman Executive Vice President and Chief Financial Officer NCR Corporation 3097 Satellite Boulevard Duluth, GA 30096
Re: NCR Corporation Form 10 -K for the Fiscal Year Ended December 31, 2016 Response dated October 27, 2017 File No. 001 -00395
Dear Mr. Fishman :
We have reviewed your October 27, 2017 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 th e 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 c omments are to comments in our October 16, 2017 letter.
Form 10 -K for the Fiscal Year Ended December 31, 2016
Management’s Discussion and Analysis of Financial Condition and Results of Operations
General
1. We note your response to prior comment 1. Please revise your qualitative discussion of cloud revenue growth in terms of prior period bookings to include a quantified discussion of your bookings and/or changes in net annual contrac t value, consistent with your earnings call transcripts and presentation slides .
Robert Fishman NCR Corporation November 2, 2017 Page 2
Form 8 -K Filed July 20, 2017
2. We note from your response to prior comment 3 that gross margin and gross margin rates by segment were provided pursuant to ASC 280 and were not intended to be non -GAAP measures. As such, please include these measures in your segment footnote pursuant to ASC 280 -10-50-27 and 28. Also, revise your segment disclosures in MD&A to include a discussion of these performance measures by segment pur suant to Section III.F. of SEC Release No. 33 -6835 and Section III.B.2 of SEC Release No. 33 -8350 .
You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3499 with any other questions.
Sincerely,
/s/ Kathleen Collins
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Mail Stop 4561 November 2, 2017 Robert Fishman Executive Vice President and Chief Financial Officer NCR Corporation 3097 Satellite Boulevard Duluth, GA 30096 Re: NCR Corporation Form 10 -K for the Fiscal Year Ended December 31, 2016 Response dated October 27, 2017 File No. 001 -00395 Dear Mr. Fishman : We have reviewed your October 27, 2017 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 th e 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 c omments are to comments in our October 16, 2017 letter. Form 10 -K for the Fiscal Year Ended December 31, 2016 Management’s Discussion and Analysis of Financial Condition and Results of Operations General 1. We note your response to prior comment 1. Please revise your qualitative discussion of cloud revenue growth in terms of prior period bookings to include a quantified discussion of your bookings and/or changes in net annual contrac t value, consistent with your earnings call transcripts and presentation slides . Robert Fishman NCR Corporation November 2, 2017 Page 2 Form 8 -K Filed July 20, 2017 2. We note from your response to prior comment 3 that gross margin and gross margin rates by segment were provided pursuant to ASC 280 and were not intended to be non -GAAP measures. As such, please include these measures in your segment footnote pursuant to ASC 280 -10-50-27 and 28. Also, revise your segment disclosures in MD&A to include a discussion of these performance measures by segment pur suant to Section III.F. of SEC Release No. 33 -6835 and Section III.B.2 of SEC Release No. 33 -8350 . You may contact Frank Knapp, Staff Accountant at (202) 551 -3805 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3499 with any other questions. Sincerely, /s/ Kathleen Collins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services