SEC Comment Letter 0000000000-24-002427 to FAIR ISAAC CORP (FICO) (CIK 0000814547) (FICO)
FAIR ISAAC CORP (FICO) (CIK 0000814547)
Date: March 4, 2024 · CIK: 0000814547 · Accession: 0000000000-24-002427
AI Filing Summary & Sentiment
File numbers found in text: 001-11689
Letter
United States securities and exchange commission logo March 4, 2024 Steven Weber Chief Financial Officer Fair Isaac Corporation 5 West Mendenhall Suite 105 Bozeman, MT 59715 Re:Fair Isaac Corporation Form 10-K for the Year Ended September 30, 2023 File No. 001-11689 Dear Steven Weber: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Year Ended September 30, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Annual Contract Value Bookings (ACV Bookings), page 32 1.Please revise your disclosure to provide context to the amount of the ACV bookings that is based on estimates of future usage-based fees and disclose whether differences between estimates and actual results have been material. Critical Accounting Policies and Estimates Revenue Recognition, page 42 2.Regarding your revenue recognition, please tell us why you have not disclosed how much each estimate and/or assumption has changed over the periods and the sensitivity of the reported amount to the methods, assumptions and estimates underlying its calculation. Refer to Item 303(b)(3) of Regulation S-K.
FirstName LastNameSteven Weber Comapany NameFair Isaac Corporation March 4, 2024 Page 2 FirstName LastName Steven Weber Fair Isaac Corporation March 4, 2024 Page 2 Item 8. Financial Statements and Supplementary Data Capitalized Software and Research and Development Costs, page 57 3.Please tell us why costs incurred to maintain and support existing products are included in research and development. Refer to ASC 730-10-55. 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 absence of action by the staff. Please contact Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 4, 2024
Steven Weber
Chief Financial Officer
Fair Isaac Corporation
5 West Mendenhall
Suite 105
Bozeman, MT 59715
Re:Fair Isaac Corporation
Form 10-K for the Year Ended September 30, 2023
File No. 001-11689
Dear Steven Weber:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Year Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Annual Contract Value Bookings (ACV Bookings), page 32
1.Please revise your disclosure to provide context to the amount of the ACV bookings that
is based on estimates of future usage-based fees and disclose whether differences between
estimates and actual results have been material.
Critical Accounting Policies and Estimates
Revenue Recognition, page 42
2.Regarding your revenue recognition, please tell us why you have not disclosed how much
each estimate and/or assumption has changed over the periods and the sensitivity of the
reported amount to the methods, assumptions and estimates underlying its calculation.
Refer to Item 303(b)(3) of Regulation S-K.
FirstName LastNameSteven Weber
Comapany NameFair Isaac Corporation
March 4, 2024 Page 2
FirstName LastName
Steven Weber
Fair Isaac Corporation
March 4, 2024
Page 2
Item 8. Financial Statements and Supplementary Data
Capitalized Software and Research and Development Costs, page 57
3.Please tell us why costs incurred to maintain and support existing products are included in
research and development. Refer to ASC 730-10-55.
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
absence of action by the staff.
Please contact Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services