SEC Comment Letter for GLOBAL PAYMENTS INC (GPN) (CIK 0001123360) (GPN) — Jul 30, 2019
GLOBAL PAYMENTS INC (GPN) (CIK 0001123360)
Date: July 30, 2019 · CIK: 0001123360 · Accession: 0000000000-19-011748
AI Filing Summary & Sentiment
Letter
July 30, 2019 Jeffrey Sloan Chief Executive Officer GLOBAL PAYMENTS INC 3550 Lenox Road Atlanta, Georgia 30326 Re:GLOBAL PAYMENTS INC Form 10-K for the fiscal year ended December 31, 2018 Filed February 21, 2019 Form 8-K filed July 30, 2019 File No. 1-16111 Dear Mr. Sloan: We have reviewed your filing and have the following comment. 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 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. Form 8-K Filed July 30, 2019 Exhibit 99.1, page 1 1.We note you disclose Adjusted net revenue plus network fees even though both six month periods ended June 30, 2018 and 2019 are properly presented with the effect of the adoption of Topic 606. It appears that this is an individually tailored revenue recognition and measurement method being substituted for a GAAP measure. Please refer to Rule 100(b) of Regulation G and question 100.04 in our Compliance & Disclosure Interpretations on Non-GAAP Measures and advise or otherwise revise your disclosure. 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 Donna Di Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding comments on the
FirstName LastNameJeffrey Sloan Comapany NameGLOBAL PAYMENTS INC July 30, 2019 Page 2 FirstName LastName Jeffrey Sloan GLOBAL PAYMENTS INC July 30, 2019 Page 2 financial statements and related matters. Please contact Lilyanna Peyser, Special Counsel, at (202) 551-3222 with any other questions. Sincerely, Division of Corporation Finance Office of Consumer Products
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July 30, 2019
Jeffrey Sloan
Chief Executive Officer
GLOBAL PAYMENTS INC
3550 Lenox Road
Atlanta, Georgia 30326
Re:GLOBAL PAYMENTS INC
Form 10-K for the fiscal year ended December 31, 2018
Filed February 21, 2019
Form 8-K filed July 30, 2019
File No. 1-16111
Dear Mr. Sloan:
We have reviewed your filing and have the following comment. 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 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.
Form 8-K Filed July 30, 2019
Exhibit 99.1, page 1
1.We note you disclose Adjusted net revenue plus network fees even though both six month
periods ended June 30, 2018 and 2019 are properly presented with the effect of the
adoption of Topic 606. It appears that this is an individually tailored revenue recognition
and measurement method being substituted for a GAAP measure. Please refer to Rule
100(b) of Regulation G and question 100.04 in our Compliance & Disclosure
Interpretations on Non-GAAP Measures and advise or otherwise revise your disclosure.
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 Donna Di
Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding comments on the
FirstName LastNameJeffrey Sloan
Comapany NameGLOBAL PAYMENTS INC
July 30, 2019 Page 2
FirstName LastName
Jeffrey Sloan
GLOBAL PAYMENTS INC
July 30, 2019
Page 2
financial statements and related matters. Please contact Lilyanna Peyser, Special Counsel, at
(202) 551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products