SEC Comment Letter 0000000000-24-005138 to Fidelity National Information Services, Inc. (FIS) (CIK 0001136893) (FIS)
Fidelity National Information Services, Inc. (FIS) (CIK 0001136893)
Date: May 6, 2024 · CIK: 0001136893 · Accession: 0000000000-24-005138
AI Filing Summary & Sentiment
File numbers found in text: 001-16427
Letter
United States securities and exchange commission logo May 6, 2024 James Kehoe Chief Financial Officer Fidelity National Information Services, Inc. 347 Riverside Avenue Jacksonville, FL 32202 Re:Fidelity National Information Services, Inc. Form 10-K for the fiscal Year Ended December 31, 2023 Form 8-K furnished February 26, 2024 File No. 001-16427 Dear James Kehoe: We have reviewed your filings and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K furnished February 26, 2024 Constant currency revenue, page 4 1.Please provide a clear description of the process for calculating the constant currency amounts. Refer to Question 104.06 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.. Free cash flow, page 9 2.Please revise the title of your free cash flow measure to adjusted free cash flow or a similar description as your calculation differs from the typical calculation of cash flows from operating activities less capital expenditures. Refer to Question 102.07 of the Non- GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameJames Kehoe Comapany NameFidelity National Information Services, Inc. May 6, 2024 Page 2 FirstName LastName James Kehoe Fidelity National Information Services, Inc. May 6, 2024 Page 2 Notes to Unaudited - Supplemental GAAP to Non-GAAP Reconciliations for the three months and years ended December 31, 2023 and 2022. Exhibit H, page 13 3.We note your adjustment for acquisition, integration and other costs includes “Enterprise transformation, including Future Forward and platform modernization.” Please tell us the nature of these costs, your consideration of Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations, including why they are not related to normal, recurring, cash operating expenses and explain why this adjustment is deemed “non-operational.” 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. Please contact Scott Stringer at 202-551-3272 or Joel Parker at 202-551-3651 if you have questions regarding our comments. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
May 6, 2024
James Kehoe
Chief Financial Officer
Fidelity National Information Services, Inc.
347 Riverside Avenue
Jacksonville, FL 32202
Re:Fidelity National Information Services, Inc.
Form 10-K for the fiscal Year Ended December 31, 2023
Form 8-K furnished February 26, 2024
File No. 001-16427
Dear James Kehoe:
We have reviewed your filings and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 8-K furnished February 26, 2024
Constant currency revenue, page 4
1.Please provide a clear description of the process for calculating the constant currency
amounts. Refer to Question 104.06 of the Non-GAAP Financial Measures Compliance
and Disclosure Interpretations..
Free cash flow, page 9
2.Please revise the title of your free cash flow measure to adjusted free cash flow or a
similar description as your calculation differs from the typical calculation of cash flows
from operating activities less capital expenditures. Refer to Question 102.07 of the Non-
GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameJames Kehoe
Comapany NameFidelity National Information Services, Inc.
May 6, 2024 Page 2
FirstName LastName
James Kehoe
Fidelity National Information Services, Inc.
May 6, 2024
Page 2
Notes to Unaudited - Supplemental GAAP to Non-GAAP Reconciliations for the three months
and years ended December 31, 2023 and 2022.
Exhibit H, page 13
3.We note your adjustment for acquisition, integration and other costs includes “Enterprise
transformation, including Future Forward and platform modernization.” Please tell us the
nature of these costs, your consideration of Question 100.01 of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations, including why they are not related
to normal, recurring, cash operating expenses and explain why this adjustment is deemed
“non-operational.”
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.
Please contact Scott Stringer at 202-551-3272 or Joel Parker at 202-551-3651 if you have
questions regarding our comments.
Sincerely,
Division of Corporation Finance
Office of Trade & Services