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SEC Comment Letter 0000000000-23-004362 to Enova International, Inc. (ENVA) (CIK 0001529864) (ENVA)

Enova International, Inc. (ENVA) (CIK 0001529864)
Date: April 28, 2023 · CIK: 0001529864 · Accession: 0000000000-23-004362

AI Filing Summary & Sentiment

File numbers found in text: 001-35503

Date
April 28, 2023
Author
Not clearly detected
Form
UPLOAD
Company
Enova International, Inc. (ENVA) (CIK 0001529864)

Letter

United States securities and exchange commission logo April 28, 2023 Steven Cunningham Chief Financial Officer Enova International, Inc. 175 West Jackson Blvd. Chicago, IL 60604 Re:Enova International, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 24, 2023 File No. 001-35503 Dear Steven Cunningham: We have limited our review of your filing to the financial statements and related disclosures 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 filed February 24, 2023 Bank Programs, page 2 1.Please tell us and revise future filings, here or in MD&A, to discuss the number of and any significant reliance on a particular bank partner and quantify the amount of revenue earned and loans purchased through your bank partner program for each period presented and discuss any trends. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance. Our Markets, page 2 2.Please tell us and revise future filings, here or in MD&A, to disclose any concentration of originations by state.

FirstName LastNameSteven Cunningham Comapany NameEnova International, Inc. April 28, 2023 Page 2 FirstName LastNameSteven Cunningham Enova International, Inc. April 28, 2023 Page 2 Products and Services, page 2 3.Please tell us and revise future filings to provide additional information for each significant loan product to allow an investor to understand the nature of your loan products. At a minimum, discuss the estimated average contractual term, the typical payment structure (e.g. - regular payments that amortize the loan to zero at maturity, interest-only payments, a single payment at maturity, etc.), the typical of fees or interest charged (e.g. – fixed interest rates, variable interest rates, one-time fee based on the principal amount, etc.), and the estimated annual percentage rate, average yield earned or average interest rate charged per loan. Please clarify if any significant loan product includes a single-pay structure and provide the key terms of this loan product. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance. Marketing, page 8 4.We note your disclosure that you have increased the percentage of loans sourced through direct marketing to 41% in 2022 and your disclosure on page 22 that the success of your business depends substantially on the willingness and ability of lead providers or marketing affiliates to provide you with customer leads at acceptable prices. Please tell us and revise future filings, here or in MD&A, to:

•disclose the percentage of loans sourced through each of your marketing channels for each period presented and discuss any trends, and •discuss the number of and any significant reliance on a particular marketing partner.

Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance. CFPB, page 13 5.We note your disclosure that you remain subject to restrictions and obligations, including a prohibition from engaging in certain conduct, related to a January 25, 2019 Consent Order with the CFPB. Please tell us and revise future filings to disclose each significant provision under the terms of the Consent Order, the actions you have taken or you plan to take to comply with each provision and the current status of your compliance. Additionally, please discuss how your actions will impact future financial results and trends including credit quality trends and discuss what the steps needed for the CFPB to terminate the Consent Order. Results of Operations, page 43 6.We note your disclosure on page 73 that revenue includes: interest income, finance charges, fees for services provided through the Company’s CSO programs, revenue on RPAs, service charges, draw fees, minimum billing fees, purchase fees, origination fees, late fees and non-sufficient funds fees. Noting the different nature the sources of revenue, please tell us and revise future filings to separately disclose each significant revenue

FirstName LastNameSteven Cunningham Comapany NameEnova International, Inc. April 28, 2023 Page 3 FirstName LastNameSteven Cunningham Enova International, Inc. April 28, 2023 Page 3 amount for each period presented and discuss any trends. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance. Loan and Finance Receivable Balances, page 48 7.Please tell us and revise future filings to explain the relationship between the average loan and finance receivable origination amount in the table at the bottom of page 49 and the average amount outstanding per loan and finance receivable amount in the table at the top of page 49. Specifically describe why the origination amount is significantly smaller than the amount outstanding. Consumer Loans and Finance Receivables, page 51 8.We note your discussion of the different revenue and credit characteristics of line of credit products here and in the small business loans section on page 54. Please tell us and revise future filings to disclose the information presented in the tables on pages 51 -54 separately for installment loans, lines of credit, and any other material loan product. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance. 9.We note your discussion related to the impact that the amount of originations has on your profitability and credit trends. Please tell us and revise future filings to include the amount of originations in the tables on pages 51-54 by loan product and discuss any trends. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance. 10.We note your discussion during your 2022 fourth quarter earnings conference call that originations from new customers during the quarter was 42% of total originations and your disclosure on page 52 that new customers typically have a higher default rate than returning customers. Please tell us and revise future filings to quantify, for each period presented, the dollar amount and percentage of originations by new customer and returning customers. To the extent there is a significant difference, please clarify if returning customers typically represent renewals of existing loans or new loans. 11.We note your discussion on page 6 that if a loan is renewed or refinanced, it is considered a new loan. Please tell us and revise your disclosure of significant accounting policies in your financial statements in future filings to discuss how you determine whether a renewal is accounted for as a new loan or as a modification. Please tell us the guidance you considered in making your determination. Current and Delinquent Loans and Finance Receivables, page 74 12.To the extent material, please tell us and revise future filings, here or in MD&A, to disclose the amount of payment deferrals in each period presented and the impact on financial results and trends.

FirstName LastNameSteven Cunningham Comapany NameEnova International, Inc. April 28, 2023 Page 4 FirstName LastName Steven Cunningham Enova International, Inc. April 28, 2023 Page 4 Note 3. Loans and Finance Receivables, page 80 13.Please tell us and revise future filings to disclose the amount of accrued interest and fees included in the principal balances in the table on the bottom of page 80. 14.Please tell us and revise future filings to clarify if “Originations and acquisitions” in the rollforward on page 81 is presented on a cost basis or a fair value basis. 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. You may contact William Schroeder at 202-551-3294 or Michael Volley at 202-551- 3437 with any questions. Sincerely, Division of Corporation Finance Office of Finance

Show Raw Text
United States securities and exchange commission logo
April 28, 2023
Steven Cunningham
Chief Financial Officer
Enova International, Inc.
175 West Jackson Blvd.
Chicago, IL 60604
Re:Enova International, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 24, 2023
File No. 001-35503
Dear Steven Cunningham:
            We have limited our review of your filing to the financial statements and related
disclosures 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 filed February 24, 2023
Bank Programs, page 2
1.Please tell us and revise future filings, here or in MD&A, to discuss the number of and
any significant reliance on a particular bank partner and quantify the amount of revenue
earned and loans purchased through your bank partner program for each period presented
and discuss any trends. Please refer to Item 303(a) of Regulation S-K and SEC Release
No. 33-8350 for guidance.
Our Markets, page 2
2.Please tell us and revise future filings, here or in MD&A, to disclose any concentration of
originations by state.

 FirstName LastNameSteven Cunningham
 Comapany NameEnova International, Inc.
 April 28, 2023 Page 2
 FirstName LastNameSteven Cunningham
Enova International, Inc.
April 28, 2023
Page 2
Products and Services, page 2
3.Please tell us and revise future filings to provide additional information for each
significant loan product to allow an investor to understand the nature of your loan
products.  At a minimum, discuss the estimated average contractual term, the typical
payment structure (e.g. - regular payments that amortize the loan to zero at maturity,
interest-only payments, a single payment at maturity, etc.), the typical of fees or interest
charged (e.g. – fixed interest rates, variable interest rates, one-time fee based on the
principal amount, etc.), and the estimated annual percentage rate, average yield earned or
average interest rate charged per loan.  Please clarify if any significant loan product
includes a single-pay structure and provide the key terms of this loan product.  Please
refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.
Marketing, page 8
4.We note your disclosure that you have increased the percentage of loans sourced through
direct marketing to 41% in 2022 and your disclosure on page 22 that the success of your
business depends substantially on the willingness and ability of lead providers or
marketing affiliates to provide you with customer leads at acceptable prices.  Please tell us
and revise future filings, here or in MD&A, to:

•disclose the percentage of loans sourced through each of your marketing channels for
each period presented and discuss any trends, and
•discuss the number of and any significant reliance on a particular marketing partner.

Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.
CFPB, page 13
5.We note your disclosure that you remain subject to restrictions and obligations, including
a prohibition from engaging in certain conduct, related to a January 25, 2019 Consent
Order with the CFPB.  Please tell us and revise future filings to disclose each significant
provision under the terms of the Consent Order, the actions you have taken or you plan to
take to comply with each provision and the current status of your compliance.
Additionally, please discuss how your actions will impact future financial results and
trends including credit quality trends and discuss what the steps needed for the CFPB to
terminate the Consent Order.
Results of Operations, page 43
6.We note your disclosure on page 73 that revenue includes: interest income, finance
charges, fees for services provided through the Company’s CSO programs, revenue on
RPAs, service charges, draw fees, minimum billing fees, purchase fees, origination fees,
late fees and non-sufficient funds fees.  Noting the different nature the sources of revenue,
please tell us and revise future filings to separately disclose each significant revenue

 FirstName LastNameSteven Cunningham
 Comapany NameEnova International, Inc.
 April 28, 2023 Page 3
 FirstName LastNameSteven Cunningham
Enova International, Inc.
April 28, 2023
Page 3
amount for each period presented and discuss any trends.  Please refer to Item 303(a) of
Regulation S-K and SEC Release No. 33-8350 for guidance.
Loan and Finance Receivable Balances, page 48
7.Please tell us and revise future filings to explain the relationship between the average loan
and finance receivable origination amount in the table at the bottom of page 49 and the
average amount outstanding per loan and finance receivable amount in the table at the top
of page 49.  Specifically describe why the origination amount is significantly smaller than
the amount outstanding.
Consumer Loans and Finance Receivables, page 51
8.We note your discussion of the different revenue and credit characteristics of line of credit
products here and in the small business loans section on page 54.  Please tell us and revise
future filings to disclose the information presented in the tables on pages 51 -54 separately
for installment loans, lines of credit, and any other material loan product.  Please refer to
Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.
9.We note your discussion related to the impact that the amount of originations has on your
profitability and credit trends.  Please tell us and revise future filings to include the
amount of originations in the tables on pages 51-54 by loan product and discuss any
trends.  Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for
guidance.
10.We note your discussion during your 2022 fourth quarter earnings conference call that
originations from new customers during the quarter was 42% of total originations and
your disclosure on page 52 that new customers typically have a higher default rate than
returning customers.  Please tell us and revise future filings to quantify, for each period
presented, the dollar amount and percentage of originations by new customer and
returning customers.  To the extent there is a significant difference, please clarify if
returning customers typically represent renewals of existing loans or new loans.
11.We note your discussion on page 6 that if a loan is renewed or refinanced, it is considered
a new loan.  Please tell us and revise your disclosure of significant accounting policies in
your financial statements in future filings to discuss how you determine whether a renewal
is accounted for as a new loan or as a modification.  Please tell us the guidance you
considered in making your determination.
Current and Delinquent Loans and Finance Receivables, page 74
12.To the extent material, please tell us and revise future filings, here or in MD&A, to
disclose the amount of payment deferrals in each period presented and the impact on
financial results and trends.

 FirstName LastNameSteven Cunningham
 Comapany NameEnova International, Inc.
 April 28, 2023 Page 4
 FirstName LastName
Steven Cunningham
Enova International, Inc.
April 28, 2023
Page 4
Note 3. Loans and Finance Receivables, page 80
13.Please tell us and revise future filings to disclose the amount of accrued interest and fees
included in the principal balances in the table on the bottom of page 80.
14.Please tell us and revise future filings to clarify if “Originations and acquisitions” in the
rollforward on page 81 is presented on a cost basis or a fair value basis.
            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.
            You may contact William Schroeder at 202-551-3294 or Michael Volley at 202-551-
3437 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance