SEC Comment Letter for TRINET GROUP, (TNET) — Jul 12, 2021
TRINET GROUP, INC.
Date: July 12, 2021 · CIK: 0000937098 · Accession: 0000000000-21-008579
AI Filing Summary & Sentiment
File numbers found in text: 001-36373
Letter
United States securities and exchange commission logo July 12, 2021 Burton Goldfield Chief Executive Officer TriNet Group, Inc. One Park Place, Suite 600 Dublin, CA 94568 Re:TriNet Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2020 Response Dated June 25, 2021 File No. 001-36373 Dear Mr. Goldfield: We have reviewed your June 25, 2021 response to our comment letter 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 the 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 June 14, 2021 letter. Form 10-K for the Fiscal Year Ended December 31, 2020 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 34 1.We note your response to comment one. Your presentation of Net Service Margin does not contemplate any cost of generating professional services revenue. In addition, while Net Service Margin and Net Insurance Service Margin contemplate insurance costs, which you previously disclosed as substantially pass-through costs, they do not contemplate any of the costs incurred to generate the related revenue. In this regard, we believe that the presentation of these measures fails to comply with Question 100.04 of the Non-GAAP Compliance and Disclosure Interpretations. Please revise accordingly.
FirstName LastNameBurton Goldfield Comapany NameTriNet Group, Inc. July 12, 2021 Page 2 FirstName LastName Burton Goldfield TriNet Group, Inc. July 12, 2021 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
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United States securities and exchange commission logo
July 12, 2021
Burton Goldfield
Chief Executive Officer
TriNet Group, Inc.
One Park Place, Suite 600
Dublin, CA 94568
Re:TriNet Group, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2020
Response Dated June 25, 2021
File No. 001-36373
Dear Mr. Goldfield:
We have reviewed your June 25, 2021 response to our comment letter 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 the 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
June 14, 2021 letter.
Form 10-K for the Fiscal Year Ended December 31, 2020
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 34
1.We note your response to comment one. Your presentation of Net Service Margin does
not contemplate any cost of generating professional services revenue. In addition, while
Net Service Margin and Net Insurance Service Margin contemplate insurance costs, which
you previously disclosed as substantially pass-through costs, they do not contemplate any
of the costs incurred to generate the related revenue. In this regard, we believe that the
presentation of these measures fails to comply with Question 100.04 of the Non-GAAP
Compliance and Disclosure Interpretations. Please revise accordingly.
FirstName LastNameBurton Goldfield
Comapany NameTriNet Group, Inc.
July 12, 2021 Page 2
FirstName LastName
Burton Goldfield
TriNet Group, Inc.
July 12, 2021
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