SEC Comment Letter for Adtalem Global Education Inc. (ATGE) (CIK 0000730464) (CVSA) — May 13, 2015
Adtalem Global Education Inc. (ATGE) (CIK 0000730464)
Date: May 13, 2015 · CIK: 0000730464 · Accession: 0000000000-15-026128
AI Filing Summary & Sentiment
Reasoning
Letter
May 13, 2015 Via E -mail Mr. Timothy J. Wiggins Chief Financial Officer DeVry Education Group Inc. 3005 Highland Parkway Downers Grove, IL 60515
Re: DeVry Education Group Inc. Form 10-K for the Year Ended June 30, 2014 Filed August 27, 2014 Form 10 -Q for the Quarter Ended March 31, 2015 Response dated April 28, 2015 File No. 1-13988
Dear Mr. Wiggins :
We have reviewed your April 28, 2015 response to our comment s and have the following comment s. 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 busine ss days by providing the requested information or advis e 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 ye ar ended June 30, 2014
Note 3 – Summary of Significant Accounting Policies, page 97 Revenue Recognition, page 98
1. We note your supplemental response to prior comment 7 and your analysis of materiality of the change in methodology for revenue recognition for withdrawn students. Please provide a detailed analysis of the qualitative factors you considered in your analysis.
Mr. Timothy J. Wiggins DeVry Education Group Inc. May 13, 2015 Page 2
Form 10 -Q for the quarter ended March 31, 2015
Note 2 Summary of significant accounting policies, page 6
Revenue recognition, page 7
2. Refer to the additional information provided on page 4 of your response regarding the reassessment and your revenue recognition policy. Please revise your revenue recognition accounting policy in future filings to disclose that since you have dete rmined that revenue associated with students who withdraw does not meet the threshold of reasonably collectible, you recognize revenue on a cash basis.
You may contact Claire DeLabar , Senior Staff Accountant, at (202) 551 -3349 or Ivette Leon, Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Terry French for
Show Raw Text
May 13, 2015 Via E -mail Mr. Timothy J. Wiggins Chief Financial Officer DeVry Education Group Inc. 3005 Highland Parkway Downers Grove, IL 60515 Re: DeVry Education Group Inc. Form 10-K for the Year Ended June 30, 2014 Filed August 27, 2014 Form 10 -Q for the Quarter Ended March 31, 2015 Response dated April 28, 2015 File No. 1-13988 Dear Mr. Wiggins : We have reviewed your April 28, 2015 response to our comment s and have the following comment s. 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 busine ss days by providing the requested information or advis e 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 ye ar ended June 30, 2014 Note 3 – Summary of Significant Accounting Policies, page 97 Revenue Recognition, page 98 1. We note your supplemental response to prior comment 7 and your analysis of materiality of the change in methodology for revenue recognition for withdrawn students. Please provide a detailed analysis of the qualitative factors you considered in your analysis. Mr. Timothy J. Wiggins DeVry Education Group Inc. May 13, 2015 Page 2 Form 10 -Q for the quarter ended March 31, 2015 Note 2 Summary of significant accounting policies, page 6 Revenue recognition, page 7 2. Refer to the additional information provided on page 4 of your response regarding the reassessment and your revenue recognition policy. Please revise your revenue recognition accounting policy in future filings to disclose that since you have dete rmined that revenue associated with students who withdraw does not meet the threshold of reasonably collectible, you recognize revenue on a cash basis. You may contact Claire DeLabar , Senior Staff Accountant, at (202) 551 -3349 or Ivette Leon, Assistant Chief Accountant, at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions. Sincerely, /s/ Terry French for Larry Spirgel Assistant Director