SEC Comment Letter for GLOBAL PAYMENTS INC (GPN) (CIK 0001123360) (GPN) — May 3, 2017
GLOBAL PAYMENTS INC (GPN) (CIK 0001123360)
Date: May 3, 2017 · CIK: 0001123360 · Accession: 0000000000-17-015523
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 May 3 , 2017 Jeffrey S. Sloan Chief Executive Officer Global Payments Inc. 10 Glenlake Parkway, North Tower Atlanta, Georgia 30328 -3473
Re: Global Payments Inc. Form 10 -K for the Transition Period Ended December 31, 2016 Filed February 28, 2017 File No. 1 -16111
Dear Mr. Sloan:
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 and any amendment you may file in response to these comments, we may have additional comments.
Notes to Consolidated Financial Statements
Note 1 – Basis of Presentation and Summary of Significant Accounting Policies
Revenue recognition, page 58
1. You disclose that certain of your integrated payments solutions arrangements contain multiple elements, such as equipment, perpetual licenses, software -as-a-service, maintenance, installation and training. Please tell us the amount of revenue recognized under these multiple element arrangements for each year presented. In addition, please tell us your consideration of disclosing the following information:
The general timing or performance of service for the deliverables within the arrangements;
Jeffrey S. Sloan Global Payments Inc. May 3 , 2017 Page 2
Performance, cancellation, termination and refund -type provisions; and
The general timing of revenue recognition for significant units of accounting.
Please refer to ASC 605 -25-50-1 and 50 -2.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Ta Tanisha Meadows, Staff Accountant, at (202) 551 -3322 or me at (202) 551 -3344 with any other questions.
Sincerely,
/s/ William H. Thompson
Show Raw Text
Mail Stop 3561 May 3 , 2017 Jeffrey S. Sloan Chief Executive Officer Global Payments Inc. 10 Glenlake Parkway, North Tower Atlanta, Georgia 30328 -3473 Re: Global Payments Inc. Form 10 -K for the Transition Period Ended December 31, 2016 Filed February 28, 2017 File No. 1 -16111 Dear Mr. Sloan: 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 and any amendment you may file in response to these comments, we may have additional comments. Notes to Consolidated Financial Statements Note 1 – Basis of Presentation and Summary of Significant Accounting Policies Revenue recognition, page 58 1. You disclose that certain of your integrated payments solutions arrangements contain multiple elements, such as equipment, perpetual licenses, software -as-a-service, maintenance, installation and training. Please tell us the amount of revenue recognized under these multiple element arrangements for each year presented. In addition, please tell us your consideration of disclosing the following information: The general timing or performance of service for the deliverables within the arrangements; Jeffrey S. Sloan Global Payments Inc. May 3 , 2017 Page 2 Performance, cancellation, termination and refund -type provisions; and The general timing of revenue recognition for significant units of accounting. Please refer to ASC 605 -25-50-1 and 50 -2. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Ta Tanisha Meadows, Staff Accountant, at (202) 551 -3322 or me at (202) 551 -3344 with any other questions. Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief Office of Consumer Products cc: David M. Sheffield, Senior Vice President and Chief Accounting Officer