SEC Comment Letter 0000000000-22-013197 to Mastercard Inc (MA) (CIK 0001141391) (MA)
Mastercard Inc (MA) (CIK 0001141391)
Date: Dec. 7, 2022 · CIK: 0001141391 · Accession: 0000000000-22-013197
AI Filing Summary & Sentiment
File numbers found in text: 001-32877
Referenced dates: August 5, 2022, July 8, 2022
Letter
United States securities and exchange commission logo December 7, 2022 Michael Miebach President and Chief Executive Officer Mastercard Inc. 2000 Purchase Street Purchase, NY 10577 Re:Mastercard Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 11, 2011 Response dated August 5, 2022 File No. 001-32877 Dear Michael Miebach: We have reviewed your August 5, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our July 25, 2022 letter. Form 10-K for the Fiscal Year Ended December 31, 2021 Notes to consolidated financial statements Note 3. Revenue, page 77 1.We have reviewed your response to our prior comment 1 in your letter dated July 8, 2022 and your response to our prior comment 2 in your letter dated August 5, 2022. We do not believe your disclosure of “gross revenue” by source with total rebates and incentives shown as a separate line, complies with the requirements of ASC 606. In this regard, we note that these categories are not revenue based on the recognition and measurement guidance in ASC Topic 606. Please revise your disclosure as appropriate.
FirstName LastNameMichael Miebach Comapany NameMastercard Inc. December 7, 2022 Page 2 FirstName LastName Michael Miebach Mastercard Inc. December 7, 2022 Page 2 You may contact Tony Watson at (202) 551-3318 or Suying Li at (202) 551-3335 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 7, 2022
Michael Miebach
President and Chief Executive Officer
Mastercard Inc.
2000 Purchase Street
Purchase, NY 10577
Re:Mastercard Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 11, 2011
Response dated August 5, 2022
File No. 001-32877
Dear Michael Miebach:
We have reviewed your August 5, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
July 25, 2022 letter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Notes to consolidated financial statements
Note 3. Revenue, page 77
1.We have reviewed your response to our prior comment 1 in your letter dated July 8, 2022
and your response to our prior comment 2 in your letter dated August 5, 2022. We do not
believe your disclosure of “gross revenue” by source with total rebates and incentives
shown as a separate line, complies with the requirements of ASC 606. In this regard, we
note that these categories are not revenue based on the recognition and measurement
guidance in ASC Topic 606. Please revise your disclosure as appropriate.
FirstName LastNameMichael Miebach
Comapany NameMastercard Inc.
December 7, 2022 Page 2
FirstName LastName
Michael Miebach
Mastercard Inc.
December 7, 2022
Page 2
You may contact Tony Watson at (202) 551-3318 or Suying Li at (202) 551-3335 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services