SEC Comment Letter for EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199) (EEFT) — Jun 30, 2016
EURONET WORLDWIDE, INC. (EEFT) (CIK 0001029199)
Date: June 30, 2016 · CIK: 0001029199 · Accession: 0000000000-16-082830
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-31648
Letter
Mail Stop 4720 June 30, 2016 Mr. Rick L. Weller Chief Financial Officer Euronet Worldwide, Inc. 3500 College Boulevard Leawood, Kansas 66211
Re: Euronet Worldwide, Inc. Form 8-K Filed April 27, 2016 File No. 001-31648
Dear Mr. Weller :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 busine ss days by providing the requested information or advis e 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 this comment , we may have additional comments.
Form 8 -K Filed on April 2 7, 2016
Exhibit 99.1 – Press Release
1. You disclose Adjusted Cash Earnings per Share, a non -GAAP financial measure, which excludes certain expenses you characterize as non -operating or non -recurring items, and describe it as a performance measure. This may be inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Please review this guidance when preparing your next earnings release. Please also tell us why you did not adjust Ad justed Cash Earnings per Share for depreciation expense and whether this measure can be used as a liquidity measure.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Secu rities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are
Rick L. Weller Euronet Worldwide, Inc. June 30, 2016 Page 2
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they h ave made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in resp onse to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities l aws of the United States.
You may contact Chris Harley at 202-551-3695 or me at 202-551-3291 if you have questions .
Sincerely,
/s/ H. Stephen Kim
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Mail Stop 4720 June 30, 2016 Mr. Rick L. Weller Chief Financial Officer Euronet Worldwide, Inc. 3500 College Boulevard Leawood, Kansas 66211 Re: Euronet Worldwide, Inc. Form 8-K Filed April 27, 2016 File No. 001-31648 Dear Mr. Weller : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 busine ss days by providing the requested information or advis e 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 this comment , we may have additional comments. Form 8 -K Filed on April 2 7, 2016 Exhibit 99.1 – Press Release 1. You disclose Adjusted Cash Earnings per Share, a non -GAAP financial measure, which excludes certain expenses you characterize as non -operating or non -recurring items, and describe it as a performance measure. This may be inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Please review this guidance when preparing your next earnings release. Please also tell us why you did not adjust Ad justed Cash Earnings per Share for depreciation expense and whether this measure can be used as a liquidity measure. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Secu rities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are Rick L. Weller Euronet Worldwide, Inc. June 30, 2016 Page 2 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they h ave made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in resp onse to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities l aws of the United States. You may contact Chris Harley at 202-551-3695 or me at 202-551-3291 if you have questions . Sincerely, /s/ H. Stephen Kim H. Stephen Kim Assistant Chief Accountant Office of Financial Services