SEC Comment Letter for EPLUS INC (PLUS) (CIK 0001022408) (PLUS) — Feb 5, 2020
EPLUS INC (PLUS) (CIK 0001022408)
Date: Feb. 5, 2020 · CIK: 0001022408 · Accession: 0000000000-20-001139
AI Filing Summary & Sentiment
Letter
February 5, 2020 Elaine Marion Chief Financial Officer EPLUS INC 13595 Dulles Technology Drive Herndon, VA 20171 Re:EPLUS INC Form 10-K for the Fiscal Year Ended March 31, 2019 Filed May 23, 2019 File No. 1-34167 Dear Ms. Marion: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended March 31, 2019 Financial Statements and Schedules 8. Notes Payable and Credit Facility, page F-24 1.Reference is made to the last paragraph on page 24 where you disclose that the credit facility restricts the ability of ePlus Technology, inc. to transfer funds to its affiliates in the form of dividends, loans or advances with certain exceptions for dividends to ePlus inc. If material, please disclose in more detail the nature of any restrictions on the ability of ePlus Technology, inc. to transfer funds to ePlus inc. in the form of cash dividends, loans or advances and disclose separately the amounts of such restricted net assets as of the end of the most recently completed fiscal year. Refer to Rule 4-08(e)(3) of Regulation S-X. Please also tell us your consideration of providing the condensed financial information prescribed by Rule 12-04 of Regulation S-X in accordance with Rule 5-04 of Regulation S-X. We remind you that the company and its management are responsible for the accuracy
FirstName LastNameElaine Marion Comapany NameEPLUS INC February 5, 2020 Page 2 FirstName LastName Elaine Marion EPLUS INC February 5, 2020 Page 2 and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Adam Phippen at (202) 551-3336 or Bill Thompson at (202) 551-3344 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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February 5, 2020
Elaine Marion
Chief Financial Officer
EPLUS INC
13595 Dulles Technology Drive
Herndon, VA 20171
Re:EPLUS INC
Form 10-K for the Fiscal Year Ended March 31, 2019
Filed May 23, 2019
File No. 1-34167
Dear Ms. Marion:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 31, 2019
Financial Statements and Schedules
8. Notes Payable and Credit Facility, page F-24
1.Reference is made to the last paragraph on page 24 where you disclose that the credit
facility restricts the ability of ePlus Technology, inc. to transfer funds to its affiliates in the
form of dividends, loans or advances with certain exceptions for dividends to ePlus inc.
If material, please disclose in more detail the nature of any restrictions on the ability of
ePlus Technology, inc. to transfer funds to ePlus inc. in the form of cash dividends, loans
or advances and disclose separately the amounts of such restricted net assets as of the end
of the most recently completed fiscal year. Refer to Rule 4-08(e)(3) of Regulation S-X.
Please also tell us your consideration of providing the condensed financial information
prescribed by Rule 12-04 of Regulation S-X in accordance with Rule 5-04 of Regulation
S-X.
We remind you that the company and its management are responsible for the accuracy
FirstName LastNameElaine Marion
Comapany NameEPLUS INC
February 5, 2020 Page 2
FirstName LastName
Elaine Marion
EPLUS INC
February 5, 2020
Page 2
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Adam Phippen at (202) 551-3336 or Bill Thompson at (202) 551-3344
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services