SEC Comment Letter 0000000000-23-009758 to Western Union CO (WU) (CIK 0001365135) (WU)
Western Union CO (WU) (CIK 0001365135)
Date: Sept. 5, 2023 · CIK: 0001365135 · Accession: 0000000000-23-009758
AI Filing Summary & Sentiment
File numbers found in text: 001-32903
Letter
United States securities and exchange commission logo September 5, 2023 Devin McGranahan President and Chief Executive Officer The Western Union Company 7001 East Belleview Avenue Denver, CO 80237 Re:The Western Union Company Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 23, 2023 Item 2.02 Form 8-K Dated July 26, 2023 File No. 001-32903 Dear Devin McGranahan: We have reviewed your filings 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. Form 10-K for Fiscal Year Ended December 31, 2022 Consolidated Financial Statements Consolidated Statements of Cash Flows, page 72 1.Please provide us with a quantified breakout for each period presented of the amounts included in the other non-cash items, net line item of your cash flows from operating activities. Please also present material amounts included in this line item as separate line items in your cash flows from operating activities. Refer to ASC 230-10-45-28. Item 2.02 Form 8-K Dated July 26, 2023 Exhibit 99.1 2.You present Adjusted EBITDA as a non-GAAP performance measure. Please revise your reconciliation of this measure to begin with net income, which is the most directly
FirstName LastNameDevin McGranahan Comapany NameThe Western Union Company September 5, 2023 Page 2 FirstName LastName Devin McGranahan The Western Union Company September 5, 2023 Page 2 comparable GAAP measure. Refer to Question 103.02 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Also, present/discuss net income margin, when Adjusted EBITDA margin is presented/discussed. 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 Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
United States securities and exchange commission logo
September 5, 2023
Devin McGranahan
President and Chief Executive Officer
The Western Union Company
7001 East Belleview Avenue
Denver, CO 80237
Re:The Western Union Company
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 23, 2023
Item 2.02 Form 8-K Dated July 26, 2023
File No. 001-32903
Dear Devin McGranahan:
We have reviewed your filings 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.
Form 10-K for Fiscal Year Ended December 31, 2022
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page 72
1.Please provide us with a quantified breakout for each period presented of the amounts
included in the other non-cash items, net line item of your cash flows from operating
activities. Please also present material amounts included in this line item as separate
line items in your cash flows from operating activities. Refer to ASC 230-10-45-28.
Item 2.02 Form 8-K Dated July 26, 2023
Exhibit 99.1
2.You present Adjusted EBITDA as a non-GAAP performance measure. Please revise your
reconciliation of this measure to begin with net income, which is the most directly
FirstName LastNameDevin McGranahan
Comapany NameThe Western Union Company
September 5, 2023 Page 2
FirstName LastName
Devin McGranahan
The Western Union Company
September 5, 2023
Page 2
comparable GAAP measure. Refer to Question 103.02 of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations. Also, present/discuss net income
margin, when Adjusted EBITDA margin is presented/discussed.
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 Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services