SEC Comment Letter 0000000000-22-012512 to Wilhelmina International, Inc. (WHLM) (CIK 0001013706) (WHLM)
Wilhelmina International, Inc. (WHLM) (CIK 0001013706)
Date: Nov. 17, 2022 · CIK: 0001013706 · Accession: 0000000000-22-012512
AI Filing Summary & Sentiment
File numbers found in text: 001-36589
Letter
United States securities and exchange commission logo November 17, 2022 James A. McCarthy Chief Financial Officer Wilhelmina International, Inc. 5420 Lyndon B Johnson Freeway, Box #25 Dallas, Texas 75240 Re:Wilhelmina International, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Response dated August 26, 2022 File No. 001-36589 Dear James A. McCarthy: We have reviewed your August 26, 2022 response to our comment letter and have the following comment. 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. Response Dated August 26, 2022 General 1.We have reviewed your accounting for the recognition of model commissions revenue through arrangements where your represented talent provides modeling and/or social media influencer services to clients pursuant to arrangements between you and the client (“direct bookings”) as it relates to principal versus agent considerations under ASC 606. Based on the information you provided, we object to your conclusion that you are the principal for direct bookings and therefore also object to your recognition of revenue related to direct bookings on a gross basis. We would not object to a conclusion whereby you are the agent for direct bookings and recognize revenue on a net basis.
FirstName LastNameJames A. McCarthy Comapany NameWilhelmina International, Inc. November 17, 2022 Page 2 FirstName LastName James A. McCarthy Wilhelmina International, Inc. November 17, 2022 Page 2 You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 if you have any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
November 17, 2022
James A. McCarthy
Chief Financial Officer
Wilhelmina International, Inc.
5420 Lyndon B Johnson Freeway, Box #25
Dallas, Texas 75240
Re:Wilhelmina International, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Response dated August 26, 2022
File No. 001-36589
Dear James A. McCarthy:
We have reviewed your August 26, 2022 response to our comment letter and have the
following comment.
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.
Response Dated August 26, 2022
General
1.We have reviewed your accounting for the recognition of model commissions revenue
through arrangements where your represented talent provides modeling and/or social
media influencer services to clients pursuant to arrangements between you and the client
(“direct bookings”) as it relates to principal versus agent considerations under ASC
606. Based on the information you provided, we object to your conclusion that you are
the principal for direct bookings and therefore also object to your recognition of
revenue related to direct bookings on a gross basis. We would not object to a conclusion
whereby you are the agent for direct bookings and recognize revenue on a net basis.
FirstName LastNameJames A. McCarthy
Comapany NameWilhelmina International, Inc.
November 17, 2022 Page 2
FirstName LastName
James A. McCarthy
Wilhelmina International, Inc.
November 17, 2022
Page 2
You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services