SEC Company Response from GLOBAL PAYMENTS INC (GPN) (CIK 0001123360) (GPN) — Nov 4, 2019
GLOBAL PAYMENTS INC (GPN) (CIK 0001123360)
Date: Nov. 4, 2019 · CIK: 0001123360 · Accession: 0001123360-19-000036
AI Filing Summary & Sentiment
Referenced dates: July 30, 2019
Letter
Via EDGAR United States Securities and Exchange Commission 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. Thompson:
This letter sets forth the response of Global Payments Inc. (the "Company") to the comment provided by the staff of the U.S. Securities and Exchange Commission (the "Staff") regarding the above-referenced filing. For your convenience, we have set forth below the Staff's comment followed by our response.
Form 8-K Filed July 30, 2019
Exhibit 99.1, page 1
1.
We reviewed your response to the prior comment in our letter dated July 30, 2019 and note your proposed disclosures related to Adjusted net revenue plus network fees. Please revise this measure in future filings to exclude the adjustment for “network fees.” The measure does not conform to Question 100.04 of the Non-GAAP Compliance and Disclosure Interpretations. The term “revenue” should not be used when discussing this measure on a gross basis.
Response:
The Company acknowledges the Staff’s comment. In future filings we will revise this measure to exclude the adjustment for “network fees”. In addition, any reference to this metric in the future will not include the term “revenue” as a descriptor.
Service. Driven. Commerce
Should you or any member of your team have any further questions or need any additional information, please contact me at (770) 829-8256.
Sincerely,
/s/ David L. Green
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CORRESP 1 filename1.htm Document Global Payments Inc. 3550 Lenox Road Atlanta, Georgia 30326 www.globalpay.com November 4, 2019 Via EDGAR William H. Thompson Accounting Branch Chief Officer of Consumer Products United States Securities and Exchange Commission Mail Stop 3561 100 F Street, NE Washington, D.C. 20549 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. Thompson: This letter sets forth the response of Global Payments Inc. (the "Company") to the comment provided by the staff of the U.S. Securities and Exchange Commission (the "Staff") regarding the above-referenced filing. For your convenience, we have set forth below the Staff's comment followed by our response. Form 8-K Filed July 30, 2019 Exhibit 99.1, page 1 1. We reviewed your response to the prior comment in our letter dated July 30, 2019 and note your proposed disclosures related to Adjusted net revenue plus network fees. Please revise this measure in future filings to exclude the adjustment for “network fees.” The measure does not conform to Question 100.04 of the Non-GAAP Compliance and Disclosure Interpretations. The term “revenue” should not be used when discussing this measure on a gross basis. Response: The Company acknowledges the Staff’s comment. In future filings we will revise this measure to exclude the adjustment for “network fees”. In addition, any reference to this metric in the future will not include the term “revenue” as a descriptor. Service. Driven. Commerce Should you or any member of your team have any further questions or need any additional information, please contact me at (770) 829-8256. Sincerely, /s/ David L. Green David L. Green Executive Vice President, General Counsel and Corporate Secretary Service. Driven. Commerce