SEC Comment Letter 0000000000-23-004047 to Adtalem Global Education Inc. (ATGE) (CIK 0000730464) (ATGE)
Adtalem Global Education Inc. (ATGE) (CIK 0000730464)
Date: April 21, 2023 · CIK: 0000730464 · Accession: 0000000000-23-004047
AI Filing Summary & Sentiment
File numbers found in text: 001-13988
Letter
United States securities and exchange commission logo April 21, 2023 Robert J. Phelan Senior Vice President and Chief Financial Officer Adtalem Global Education Inc. 500 West Monroe Street Chicago, IL 60061 Re:Adtalem Global Education Inc. Form 10-K for Fiscal Year Ended June 30, 2022 File No. 001-13988 Dear Robert J. Phelan: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 comments. Form 10-K for Fiscal Year Ended June 30, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures and Reconciliations, page 78 1.Refer to your non-GAAP financial measures Net income from continuing operations excluding special items, Earnings per share from continuing operations excluding special items, and Operating income excluding special items. It appears that the reconciliations for these non-GAAP financial measures include an adjustment for"restructuring expense" which you have incurred every year since 2012. Please tell us your consideration as to whether these charges represent normal, recurring, cash operating expenses necessary for your core operations. Refer to Question 100.01 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please note that this comment also applies to the non-GAAP measures presented in your Form10-Q and Item 2.02, Form 8-K. In closing, 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
FirstName LastNameRobert J. Phelan Comapany NameAdtalem Global Education Inc. April 21, 2023 Page 2 FirstName LastName Robert J. Phelan Adtalem Global Education Inc. April 21, 2023 Page 2 absence of action by the staff. You may contact Stephen Kim at 202-551-3291 or Theresa Brillant at 202-551-3307 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
April 21, 2023
Robert J. Phelan
Senior Vice President and Chief Financial Officer
Adtalem Global Education Inc.
500 West Monroe Street
Chicago, IL 60061
Re:Adtalem Global Education Inc.
Form 10-K for Fiscal Year Ended June 30, 2022
File No. 001-13988
Dear Robert J. Phelan:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. 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 comments.
Form 10-K for Fiscal Year Ended June 30, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures and Reconciliations, page 78
1.Refer to your non-GAAP financial measures Net income from continuing operations
excluding special items, Earnings per share from continuing operations excluding special
items, and Operating income excluding special items. It appears that the reconciliations
for these non-GAAP financial measures include an adjustment for"restructuring expense"
which you have incurred every year since 2012. Please tell us your consideration as to
whether these charges represent normal, recurring, cash operating expenses necessary for
your core operations. Refer to Question 100.01 of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures. Please note that this comment also
applies to the non-GAAP measures presented in your Form10-Q and Item 2.02, Form 8-K.
In closing, 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
FirstName LastNameRobert J. Phelan
Comapany NameAdtalem Global Education Inc.
April 21, 2023 Page 2
FirstName LastName
Robert J. Phelan
Adtalem Global Education Inc.
April 21, 2023
Page 2
absence of action by the staff.
You may contact Stephen Kim at 202-551-3291 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services