SEC Comment Letter for EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199) (EEFT) — Jul 23, 2009
EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199)
Date: July 23, 2009 · CIK: 0001029199 · Accession: 0000000000-09-039308
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-31648
Referenced dates: June 30, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 4720 July 23, 2009 By U.S. Mail and Facsimile to: (913) 327-1921 Rick L. Weller Chief Financial Officer Euronet Worldwide, Inc. 4601 College Boulevard, Suite 300 Leawood, Kansas 66211
Re: Euronet Worldwide, Inc. Form 10-K for the Fiscal Year Ended December 31, 2008 Filed March 2, 2009 File No. 001-31648
Dear Mr. Weller:
We have reviewed your response filed with the Commission on July 14, 2009 and have the following comment. Where i ndicated, we think you should revise your documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please be as detailed as necessary in your explan ation. In our comment, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Feel free to call us at th e telephone numbers listed at the end of th is letter. Form 10-K for the Fiscal Year Ended December 31, 2008
Item 11. Executive Compensation, page 98
Compensation Discussion and Analysis, page 27 of Definitive Proxy Statement on Schedule 14A
Annual Bonus, page 30 of Definitive Proxy Statement on Schedule 14A
1. We note your July 14, 2009 response to co mment 1 in our letter dated June 30, 2009. We are not persuaded by your arguments not to provide the information in next year’s proxy statement, and we contin ue to believe that shareholders should be provided with performance target information. Please provide us with proposed revised disclosure that incl udes the performance targets for 2008 and
Rick L. Weller Euronet Worldwide, Inc. July 23, 2009 Page 2
confirm that the company will disclose similar performance targets in future filings. Closing Comments
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comment and provides any requested information. Detailed cover lette rs greatly facilitate our review. Please understand that we may have additional commen ts after reviewing your response to our comment. Please contact Justin Dobbie at (202) 551-3469 or me at (202) 551-3418 with any questions. Sincerely,
William Friar Senior Financial Analyst
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 4720
July 23, 2009
By U.S. Mail and Facsimile to: (913) 327-1921
Rick L. Weller Chief Financial Officer Euronet Worldwide, Inc. 4601 College Boulevard, Suite 300 Leawood, Kansas 66211
Re: Euronet Worldwide, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2008
Filed March 2, 2009
File No. 001-31648
Dear Mr. Weller:
We have reviewed your response filed with the Commission on July 14, 2009 and
have the following comment. Where i ndicated, we think you should revise your
documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please
be as detailed as necessary in your explan ation. In our comment, we may ask you to
provide us with information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Feel free to call us at th e telephone numbers listed at the end of th is letter.
Form 10-K for the Fiscal Year Ended December 31, 2008
Item 11. Executive Compensation, page 98
Compensation Discussion and Analysis, page 27 of Definitive Proxy Statement on
Schedule 14A
Annual Bonus, page 30 of Definitive Proxy Statement on Schedule 14A
1. We note your July 14, 2009 response to co mment 1 in our letter dated June 30,
2009. We are not persuaded by your arguments not to provide the information in
next year’s proxy statement, and we contin ue to believe that shareholders should
be provided with performance target information. Please provide us with
proposed revised disclosure that incl udes the performance targets for 2008 and
Rick L. Weller
Euronet Worldwide, Inc. July 23, 2009 Page 2
confirm that the company will disclose similar performance targets in future
filings.
Closing Comments
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our
comment and provides any requested information. Detailed cover lette rs greatly facilitate
our review. Please understand that we may have additional commen ts after reviewing
your response to our comment. Please contact Justin Dobbie at (202) 551-3469 or me at (202) 551-3418 with any
questions.
Sincerely,
William Friar Senior Financial Analyst