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SEC Comment Letter for GREEN DOT CORP (GDOT) (CIK 0001386278) (GDOT) — Oct 2, 2019

GREEN DOT CORP (GDOT) (CIK 0001386278)
Date: Oct. 2, 2019 · CIK: 0001386278 · Accession: 0000000000-19-014207

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File numbers found in text: 001-34819

Date
October 2, 2019
Author
Office of Finance
Form
UPLOAD
Company
GREEN DOT CORP (GDOT) (CIK 0001386278)

Letter

October 2, 2019 Steven W. Streit Chief Executive Officer Green Dot Corp 3465 E. Foothill Blvd. Pasadena, CA 91107 Re:Green Dot Corp Form 10-K for the fiscal year ended December 31, 2018 Filed February 27, 2019 Form 10-Q for the period ending June 30, 2019 Filed August 9, 2019 File Number 001-34819 Dear Mr. Streit: We have reviewed your September 30, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our September 9, 2019 letter. Form 10-Q for the Period Ending June 30, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Comparision of Three-Month Periods Ended June 30, 2019 and 2018 Operating Revenues, page 33 1.We note your response to comment 1. Considering that your revised 2019 guidance was in part attributable to the decline in your legacy non-direct deposit active accounts as discussed in your Q2 2019 earnings call, in future filings, please disaggregate Gross Dollar Volume and Number of Active Accounts between direct deposit active accounts and non-direct deposit active accounts.

FirstName LastNameSteven W. Streit Comapany NameGreen Dot Corp October 2, 2019 Page 2 FirstName LastName Steven W. Streit Green Dot Corp October 2, 2019 Page 2

You may contact Christina Harley at 202-551-3695 or Michelle Miller at 202-551-3368 with any questions. Sincerely, Division of Corporation Finance Office of Finance

Show Raw Text
October 2, 2019
Steven W. Streit
Chief Executive Officer
Green Dot Corp
3465 E. Foothill Blvd.
Pasadena, CA 91107
Re:Green Dot Corp
Form 10-K for the fiscal year ended December 31, 2018
Filed February 27, 2019
Form 10-Q for the period ending June 30, 2019
Filed August 9, 2019
File Number 001-34819
Dear Mr. Streit:
            We have reviewed your September 30, 2019 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
September 9, 2019 letter.
Form 10-Q for the Period Ending June 30, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Comparision of Three-Month Periods Ended June 30, 2019 and 2018
Operating Revenues, page 33
1.We note your response to comment 1.  Considering that your revised 2019 guidance was
in part attributable to the decline in your legacy non-direct deposit active accounts as
discussed in your Q2 2019 earnings call, in future filings, please disaggregate Gross
Dollar Volume and Number of Active Accounts between direct deposit active accounts
and non-direct deposit active accounts.

 FirstName LastNameSteven W.  Streit
 Comapany NameGreen Dot Corp
 October 2, 2019 Page 2
 FirstName LastName
Steven W.  Streit
Green Dot Corp
October 2, 2019
Page 2

            You may contact Christina Harley at 202-551-3695 or Michelle Miller at 202-551-3368
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance