SEC Comment Letter for NCR Voyix Corp (VYX, NCRRP) (CIK 0000070866) (VYX) — Nov 22, 2017
NCR Voyix Corp (VYX, NCRRP) (CIK 0000070866)
Date: Nov. 22, 2017 · CIK: 0000070866 · Accession: 0000000000-17-041350
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Letter
Mail Stop 4561 November 21, 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 November 16, 2017 File No. 001 -00395
Dear Mr. Fishman :
We have reviewed your November 16, 2017 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional co mments. Unless we note otherwise, our references to prior comments are to comments in our November 2, 2017 letter.
1. You state in your response to prior comment 2 that segment operating income is the measure of profit or loss used by the chief operating decision maker (CODM) to allocate resources and assess performance. Please tell us whether segment gross margin and segment gross margin rates are also regularly provided to and reviewed by your CODM. If so, tell us how such measures are used by your CODM in assessing performance or allocating resources. To the extent that your CODM uses more than one measure to allocate resources or assess segment performance, tell us how you applied the guidance in ASC 280 -10-50-28 in determining the segment measure or measures to be reported .
Robert Fishman NCR Corporation November 21, 2017 Page 2
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 Col lins
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Mail Stop 4561 November 21, 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 November 16, 2017 File No. 001 -00395 Dear Mr. Fishman : We have reviewed your November 16, 2017 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional co mments. Unless we note otherwise, our references to prior comments are to comments in our November 2, 2017 letter. 1. You state in your response to prior comment 2 that segment operating income is the measure of profit or loss used by the chief operating decision maker (CODM) to allocate resources and assess performance. Please tell us whether segment gross margin and segment gross margin rates are also regularly provided to and reviewed by your CODM. If so, tell us how such measures are used by your CODM in assessing performance or allocating resources. To the extent that your CODM uses more than one measure to allocate resources or assess segment performance, tell us how you applied the guidance in ASC 280 -10-50-28 in determining the segment measure or measures to be reported . Robert Fishman NCR Corporation November 21, 2017 Page 2 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 Col lins Kathleen Collins Accounting Branch Chief Office of Information Technologies and Services