SEC Comment Letter 0000000000-24-009211 to Paysign, Inc. (PAYS) (CIK 0001496443) (PAYS)
Paysign, Inc. (PAYS) (CIK 0001496443)
Date: Aug. 12, 2024 · CIK: 0001496443 · Accession: 0000000000-24-009211
AI Filing Summary & Sentiment
File numbers found in text: 001-38623
Letter
August 12, 2024 Jeff Baker Chief Financial Officer Paysign, Inc. 2615 St. Rose Parkway Henderson, Nevada 89052 Re:Paysign, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-38623 Dear Jeff Baker: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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. Form 10-K for Fiscal Year Ended December 31, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Comparison of Year Ended December 31, 2023 to Year Ended December 31, 2022, page 24 1.Please revise to quantify factors to which changes are attributed throughout your results of operations discussion. For example, we note your disclosure that the increase in cost of revenues during fiscal year 2023 was primarily due to an increase in cardholder usage activity and associated network expenses such as interchange and ATM costs, an increase in plastics and collateral related to an increase in the number of unique card loads, an increase in network expenses and sales commissions related to the growth in your pharma patient affordability business, and an increase in customer service expenses associated with wage inflation pressures and the overall growth in your business, offset by a decline in postage. Refer to 303(b) of Regulation S-K.
August 12, 2024 Page 2 Notes to Consolidated Financial Statements 2. Summary of Significant Accounting Policies, page F-7 2.Please disclose all required information regarding your segment(s) in accordance with ASC 280-10-50. Provide us with a copy of your intended revised disclosure. In closing, 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. Please contact Stephen Kim at 202-551-3291 or Theresa Brillant at 202-551-3307 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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August 12, 2024
Jeff Baker
Chief Financial Officer
Paysign, Inc.
2615 St. Rose Parkway
Henderson, Nevada 89052
Re:Paysign, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-38623
Dear Jeff Baker:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Comparison of Year Ended December 31, 2023 to Year Ended December 31, 2022, page 24
1.Please revise to quantify factors to which changes are attributed throughout your results of
operations discussion. For example, we note your disclosure that the increase in cost of
revenues during fiscal year 2023 was primarily due to an increase in cardholder usage
activity and associated network expenses such as interchange and ATM costs, an increase
in plastics and collateral related to an increase in the number of unique card loads, an
increase in network expenses and sales commissions related to the growth in your pharma
patient affordability business, and an increase in customer service expenses associated
with wage inflation pressures and the overall growth in your business, offset by a decline
in postage. Refer to 303(b) of Regulation S-K.
August 12, 2024
Page 2
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies, page F-7
2.Please disclose all required information regarding your segment(s) in accordance with
ASC 280-10-50. Provide us with a copy of your intended revised disclosure.
In closing, 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.
Please contact Stephen Kim at 202-551-3291 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services