SEC Comment Letter for ExlService Holdings, Inc. (EXLS) (CIK 0001297989) (EXLS) — Mar 8, 2016
ExlService Holdings, Inc. (EXLS) (CIK 0001297989)
Date: March 8, 2016 · CIK: 0001297989 · Accession: 0000000000-16-067607
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33089
Letter
UNITED STATES SECURIT IES AND EXCHANGE COMMISS ION DIVISION OF CORPORATION FINANCE Mail Stop 3561 ExlService Holdings, Inc. Vishal Chhibbar Chief Financial Officer 280 Park A venue, 38th Floor New York, New York 10017 WASHINGTON, D.C. 2.0549 December 22, 2015 Re: ExlService Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Filed February 27, 2015 File No. 001-33089 Dear Mr. Chhibbar: 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 to these comments, we may have additional comments. Item 7 A. Quantitative and Qualitative Disclosures About Market Risk, page 63 1. Please provide an analysis on whether your "cash flow hedges," discussed in f:he second to-last paragraph of page 63, are material, such that you would need to provide the disclosure in Item 305(a) of Regulation S-K. Please see General Instruction 5.B to Item 305(a) and (b). We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company's disclosure , they are responsib le for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledg ing that:
ExlService Holdings, Inc. Vishal Chhibbar December 22, 2015 Page2 • the company is responsible for.the adequacy and accuracy of the disclosure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact Charlie Guidry, Staff Attorney, at 202-551-3621 or me at 202-551-3264 with any questions. Sincerely, Mara L. Ransom Assistant Director Office of Consumer Products
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UNITED STATES SECURIT IES AND EXCHANGE COMMISS ION DIVISION OF CORPORATION FINANCE Mail Stop 3561 ExlService Holdings, Inc. Vishal Chhibbar Chief Financial Officer 280 Park A venue, 38th Floor New York, New York 10017 WASHINGTON, D.C. 2.0549 December 22, 2015 Re: ExlService Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Filed February 27, 2015 File No. 001-33089 Dear Mr. Chhibbar: 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 to these comments, we may have additional comments. Item 7 A. Quantitative and Qualitative Disclosures About Market Risk, page 63 1. Please provide an analysis on whether your "cash flow hedges," discussed in f:he second to-last paragraph of page 63, are material, such that you would need to provide the disclosure in Item 305(a) of Regulation S-K. Please see General Instruction 5.B to Item 305(a) and (b). We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company's disclosure , they are responsib le for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledg ing that: ExlService Holdings, Inc. Vishal Chhibbar December 22, 2015 Page2 • the company is responsible for.the adequacy and accuracy of the disclosure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact Charlie Guidry, Staff Attorney, at 202-551-3621 or me at 202-551-3264 with any questions. Sincerely, Mara L. Ransom Assistant Director Office of Consumer Products