SEC Comment Letter for PAYCHEX INC (PAYX) (CIK 0000723531) (PAYX) — Feb 27, 2020
PAYCHEX INC (PAYX) (CIK 0000723531)
Date: Feb. 27, 2020 · CIK: 0000723531 · Accession: 0000000000-20-001792
AI Filing Summary & Sentiment
File numbers found in text: 000-11330
Letter
February 27, 2020 Martin Mucci President and Chief Executive Officer Paychex, Inc. 911 Panorama Trail South Rochester, New York 14625-2396 Re:Paychex, Inc. Form 10-K for the Fiscal Year Ended May 31, 2019 Filed July 24, 2019 File No. 000-11330 Dear Mr. Mucci: We have reviewed your filing 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. Form 10-K for the Fiscal Year Ended May 31, 2019 Consolidated Financial Statements Consolidated Statements of Income and Comprehensive Income, page 40 1.Please tell us and present separately in your financial statements the material components of the operating expenses line item. Refer to Rule 5-03.3 of Regulation S-X. Please also tell us and disclose in an accounting policy footnote the types of amounts included in operating expenses versus selling, general and administrative expenses. Note B - Service Revenue Assets Recognized from the Costs to Obtain and Fulfill Contracts, page 55 2.Please tell us the specific types of incremental costs of obtaining a contract that you have recognized as an asset. Also, tell us separately for each type of incremental cost how you determined the asset recognition criteria in paragraphs 25-1 through 25-3 of ASC 340-40- 25 were met.
FirstName LastNameMartin Mucci Comapany NamePaychex, Inc. February 27, 2020 Page 2 FirstName LastName Martin Mucci Paychex, Inc. February 27, 2020 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Keira Nakada at (202) 551-3659 or Rufus Decker at (202) 551- 3769 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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February 27, 2020
Martin Mucci
President and Chief Executive Officer
Paychex, Inc.
911 Panorama Trail South
Rochester, New York 14625-2396
Re:Paychex, Inc.
Form 10-K for the Fiscal Year Ended May 31, 2019
Filed July 24, 2019
File No. 000-11330
Dear Mr. Mucci:
We have reviewed your filing 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.
Form 10-K for the Fiscal Year Ended May 31, 2019
Consolidated Financial Statements
Consolidated Statements of Income and Comprehensive Income, page 40
1.Please tell us and present separately in your financial statements the material components
of the operating expenses line item. Refer to Rule 5-03.3 of Regulation S-X. Please also
tell us and disclose in an accounting policy footnote the types of amounts included in
operating expenses versus selling, general and administrative expenses.
Note B - Service Revenue
Assets Recognized from the Costs to Obtain and Fulfill Contracts, page 55
2.Please tell us the specific types of incremental costs of obtaining a contract that you have
recognized as an asset. Also, tell us separately for each type of incremental cost how you
determined the asset recognition criteria in paragraphs 25-1 through 25-3 of ASC 340-40-
25 were met.
FirstName LastNameMartin Mucci
Comapany NamePaychex, Inc.
February 27, 2020 Page 2
FirstName LastName
Martin Mucci
Paychex, Inc.
February 27, 2020
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Keira Nakada at (202) 551-3659 or Rufus Decker at (202) 551-
3769 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services