SEC Comment Letter 0000000000-23-013256 to TIPTREE INC. (TIPT) (CIK 0001393726) (TIPT)
TIPTREE INC. (TIPT) (CIK 0001393726)
Date: Dec. 5, 2023 · CIK: 0001393726 · Accession: 0000000000-23-013256
AI Filing Summary & Sentiment
File numbers found in text: 001-33549
Letter
United States securities and exchange commission logo December 5, 2023 Scott McKinney Chief Financial Officer Tiptree Inc. 660 Steamboat Road Greenwich, Connecticut 06830 Re:Tiptree Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed March 8, 2023 Response Filed November 30, 2023 File No. 001-33549 Dear Scott McKinney: We have reviewed your November 30, 2023 response to our comment letter and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our November 15, 2023 letter. Form 10-K for Fiscal Year Ended December 31, 2022 Market Opportunity, page 15 1.Please refer to prior comment 2. Based on the premium equivalents term used for this metric, it's use, and its disclosure related to descriptions of revenue, deferred revenue and revenue trends in your December 31, 2022, Form 10-K, it appears that including amounts that will not be recognized as revenue based on the terms of the contract as premium equivalents is potentially misleading. Therefore, please revise future filings to not include these amounts as premium equivalents, revise prior period amounts to conform to the new measurement and provide appropriate disclosure that discusses the change in calculation. Refer to SEC Release 34-88094 for guidance.
FirstName LastNameScott McKinney Comapany NameTiptree Inc. December 5, 2023 Page 2 FirstName LastName Scott McKinney Tiptree Inc. December 5, 2023 Page 2
Please contact Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 5, 2023
Scott McKinney
Chief Financial Officer
Tiptree Inc.
660 Steamboat Road
Greenwich, Connecticut 06830
Re:Tiptree Inc.
Form 10-K for Fiscal Year Ended December 31, 2022 Filed March 8, 2023
Response Filed November 30, 2023
File No. 001-33549
Dear Scott McKinney:
We have reviewed your November 30, 2023 response to our comment letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in our November 15,
2023 letter.
Form 10-K for Fiscal Year Ended December 31, 2022
Market Opportunity, page 15
1.Please refer to prior comment 2. Based on the premium equivalents term used for this
metric, it's use, and its disclosure related to descriptions of revenue, deferred revenue and
revenue trends in your December 31, 2022, Form 10-K, it appears that including amounts
that will not be recognized as revenue based on the terms of the contract as premium
equivalents is potentially misleading. Therefore, please revise future filings to not include
these amounts as premium equivalents, revise prior period amounts to conform to the new
measurement and provide appropriate disclosure that discusses the change in calculation.
Refer to SEC Release 34-88094 for guidance.
FirstName LastNameScott McKinney
Comapany NameTiptree Inc.
December 5, 2023 Page 2
FirstName LastName
Scott McKinney
Tiptree Inc.
December 5, 2023
Page 2
Please contact Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Finance