SEC Comment Letter for PAYCHEX INC (PAYX) (CIK 0000723531) (PAYX) — Mar 19, 2020
PAYCHEX INC (PAYX) (CIK 0000723531)
Date: March 19, 2020 · CIK: 0000723531 · Accession: 0000000000-20-002425
AI Filing Summary & Sentiment
File numbers found in text: 000-11330
Letter
March 18, 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 Response dated March 11, 2020 File No. 000-11330 Dear Mr. Mucci: We have reviewed your March 11, 2020 response to our comment letter and have the following comment. In our comment, we 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 the comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February 27, 2020 letter. Form 10-K for the Fiscal Year Ended May 31, 2019 Consolidated Financial Statements Note B - Service Revenue Assets Recognized from the Costs to Obtain and Fulfill Contracts, page 55 1.We read your response to comment 2. Please also tell us and disclose your accounting policy for incremental costs of obtaining a contract renewal, including whether a commission paid for a renewal is commensurate with a commission paid on the initial contract, any material differences in the incremental costs capitalized for a contract renewal versus the initial contract and the amortization period for incremental costs capitalized upon obtaining a contract renewal. Refer to ASC 340-40-50-2 and Revenue Recognition Transition Resource Group Memo No. 23.
FirstName LastNameMartin Mucci Comapany NamePaychex, Inc. March 18, 2020 Page 2 FirstName LastName Martin Mucci Paychex, Inc. March 18, 2020 Page 2
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
Show Raw Text
March 18, 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
Response dated March 11, 2020
File No. 000-11330
Dear Mr. Mucci:
We have reviewed your March 11, 2020 response to our comment letter and have the
following comment. In our comment, we 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 the comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February 27, 2020 letter.
Form 10-K for the Fiscal Year Ended May 31, 2019
Consolidated Financial Statements
Note B - Service Revenue
Assets Recognized from the Costs to Obtain and Fulfill Contracts, page 55
1.We read your response to comment 2. Please also tell us and disclose your accounting
policy for incremental costs of obtaining a contract renewal, including whether a
commission paid for a renewal is commensurate with a commission paid on the initial
contract, any material differences in the incremental costs capitalized for a contract
renewal versus the initial contract and the amortization period for incremental costs
capitalized upon obtaining a contract renewal. Refer to ASC 340-40-50-2 and Revenue
Recognition Transition Resource Group Memo No. 23.
FirstName LastNameMartin Mucci
Comapany NamePaychex, Inc.
March 18, 2020 Page 2
FirstName LastName
Martin Mucci
Paychex, Inc.
March 18, 2020
Page 2
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