SEC Comment Letter for Atlanticus Holdings Corp (ATLC, ATLCL, ATLCP, ATLCZ) (CIK 0001464343) (ATLC) — Jan 22, 2018
Atlanticus Holdings Corp (ATLC, ATLCL, ATLCP, ATLCZ) (CIK 0001464343)
Date: Jan. 22, 2018 · CIK: 0001464343 · Accession: 0000000000-18-002283
AI Filing Summary & Sentiment
File numbers found in text: 000-53717
Letter
Mail Stop 4720 January 22, 2018 William R. McCamey Chief Financial Officer Atlanticus Holding Corporation Five Concourse Parkway, Suite 300 Atlanta, Georgia 30328
Re: Atlanticus Holding Corporation Form 10 -K for the Fis cal Year Ended December 31, 2016 Response Dated January 2, 2018 File No. 000-53717
Dear Mr. McCamey :
We have reviewed your January 2, 2018 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 busine ss days by providing the requested information or advis e 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 no te otherwise, our references to prior comments are to co mments in our December 5, 2017 letter .
Form 10 -K for the Fiscal Year Ended December 31, 2016
Item 1. Business
How Do We Collect?, page 3
1. We note your response to comment one that you consider loans past due 90 days or more and re -aged as troubled debt restructurings. Please revise future filings to include the disclosure required by ASC 310 -40-50.
William R. McCamey Atlanticus Holding Corp oration January 22, 2018 Page 2
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Definitions of Financial Operating and Statistical Measures, page 28
2. Please provide us a quantitative reconciliation to the most directly comparable GAAP measure for your non -GAAP measures Total Yield Ratio, Combined Gross Charge -off Ratio, an d Adjusted C harge -off Ratio for the years ended 12/31/2016 and 12/31/2015. Please clearly describe the nature of each adjustment and the reasons why the adjustments are relevant and useful.
You may contact William Schroeder, Staff Accountant, at (202) 551 -3294 or me at (202) 551-3437 with any questions.
Sincerely,
/s/ Michael Volley
Show Raw Text
Mail Stop 4720
January 22, 2018
William R. McCamey
Chief Financial Officer
Atlanticus Holding Corporation
Five Concourse Parkway, Suite 300
Atlanta, Georgia 30328
Re: Atlanticus Holding Corporation
Form 10 -K for the Fis cal Year Ended December 31, 2016
Response Dated January 2, 2018
File No. 000-53717
Dear Mr. McCamey :
We have reviewed your January 2, 2018 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 busine ss days by providing the requested
information or advis e 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 no te otherwise, our references to prior comments are to co mments in our December 5,
2017 letter .
Form 10 -K for the Fiscal Year Ended December 31, 2016
Item 1. Business
How Do We Collect?, page 3
1. We note your response to comment one that you consider loans past due 90 days or more
and re -aged as troubled debt restructurings. Please revise future filings to include the
disclosure required by ASC 310 -40-50.
William R. McCamey
Atlanticus Holding Corp oration
January 22, 2018
Page 2
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Definitions of Financial Operating and Statistical Measures, page 28
2. Please provide us a quantitative reconciliation to the most directly comparable GAAP
measure for your non -GAAP measures Total Yield Ratio, Combined Gross Charge -off
Ratio, an d Adjusted C harge -off Ratio for the years ended 12/31/2016 and 12/31/2015.
Please clearly describe the nature of each adjustment and the reasons why the
adjustments are relevant and useful.
You may contact William Schroeder, Staff Accountant, at (202) 551 -3294 or me at (202)
551-3437 with any questions.
Sincerely,
/s/ Michael Volley
Michael Volley
Staff Accountant
Office of Financial Services