SEC Comment Letter for CREDIT ACCEPTANCE CORP (CACC) (CIK 0000885550) (CACC) — Dec 9, 2020
CREDIT ACCEPTANCE CORP (CACC) (CIK 0000885550)
Date: Dec. 9, 2020 · CIK: 0000885550 · Accession: 0000000000-20-011801
AI Filing Summary & Sentiment
File numbers found in text: 000-20202
Letter
United States securities and exchange commission logo December 9, 2020 Kenneth Booth Chief Financial Officer Credit Acceptance Corp 25505 W. Twelve Mile Road Southfield, Michigan 48034 Re:Credit Acceptance Corp Form 8-K filed October 29, 2020 File No. 000-20202 Dear Mr. Booth: We have reviewed your filing and have the following comment. 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 8-K Filed October 29, 2020 Exhibit 99.1, page 1 1.We note your disclosure of various non-GAAP measures that exclude "GAAP Provision for credit losses (after tax),” including adjusted net income, adjusted net income per diluted share, adjusted net income plus interest expense (after tax), economic profit, and adjusted return on capital. It appears these performance measures substitute individually tailored recognition and measurement methods for those of GAAP and violate Rule 100(b) of Regulation G. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations, which is available on our website at: http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm. Please refrain from disclosing these performance measures, or any other similar non-GAAP performance measures that exclude all or a portion of the provision for credit losses.
FirstName LastNameKenneth Booth Comapany NameCredit Acceptance Corp December 9, 2020 Page 2 FirstName LastName Kenneth Booth Credit Acceptance Corp December 9, 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 Michael Volley, Staff Accountant, at 202-551-3437 or Amit Pande, Accounting Branch Chief, at 202-551-3423 if you have any questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 9, 2020
Kenneth Booth
Chief Financial Officer
Credit Acceptance Corp
25505 W. Twelve Mile Road
Southfield, Michigan 48034
Re:Credit Acceptance Corp
Form 8-K filed October 29, 2020
File No. 000-20202
Dear Mr. Booth:
We have reviewed your filing and have the following comment. 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 8-K Filed October 29, 2020
Exhibit 99.1, page 1
1.We note your disclosure of various non-GAAP measures that exclude "GAAP Provision
for credit losses (after tax),” including adjusted net income, adjusted net income per
diluted share, adjusted net income plus interest expense (after tax), economic profit, and
adjusted return on capital. It appears these performance measures substitute individually
tailored recognition and measurement methods for those of GAAP and violate Rule
100(b) of Regulation G. Refer to Question 100.04 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations, which is available on our website at:
http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm. Please refrain from
disclosing these performance measures, or any other similar non-GAAP performance
measures that exclude all or a portion of the provision for credit losses.
FirstName LastNameKenneth Booth
Comapany NameCredit Acceptance Corp
December 9, 2020 Page 2
FirstName LastName
Kenneth Booth
Credit Acceptance Corp
December 9, 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 Michael Volley, Staff Accountant, at 202-551-3437 or Amit Pande,
Accounting Branch Chief, at 202-551-3423 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Finance