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SEC Comment Letter for Yiren Digital (YRD) — Sep 28, 2017

Yiren Digital Ltd.
Date: Sept. 28, 2017 · CIK: 0001631761 · Accession: 0000000000-17-034560

AI Filing Summary & Sentiment

Date
December 31, 2016
Author
/s/ Michael Volley
Form
UPLOAD
Company
Yiren Digital Ltd.

Letter

Mail Stop 4720 September 28 , 2017 Yu Cong Chief Financial Officer Yirendai Ltd. 10/F, Building 9,91 Jianguo Road Chaoyang District, Beijing 100022 The People’s Republic of China

Re: Yirendai Ltd. Form 20 -F for the Fiscal Year Ended December 31, 2016 Filed April 24, 2017 Response Dated September 1, 2017 File No. 001 -37657

Dear Mr. Cong :

We have reviewed your September 1, 2017 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 comments in our August 7, 2017 letter .

Form 20 -F for the Fiscal Year Ended December 31, 2016

Item 4. Information on the Company – Organizational Structure, page 77

1. Please revise the diagram illustrat ing your corporate structure and the discussion which follows in future filings to incorporate all of your consolidated entities, including the ABFEs discussed on page F -10.

Item 5. Operating and Financial Review and Prospects, page 83

2. We note your response to comment 3 . Please revise your disclosure of loans facilitated by channel on page 54 and by grade on page 89 or similar disclosure in future filings to present

Yu Cong Yirendai Ltd. September 28, 2017 Page 2

the percentage of the total amount of originations for each channel or grade. Also, to the extent change s or trends in originations by channel or grade result in an impact on your origination volume and/or financial results, please provide appropriate discussion and analysis .

3. We note your response to comment 3. To the extent changes or trends in maturit ies of your loans result in an impact on your origination volume and/or financial results, please revise future filings to p rovide appropriate discussion and analysis.

4. We note your response s and proposed disclosure to comment s 4 and 5. Please revise future filings to provide a ppropriate discuss ion and analy sis of any significant changes or trends in new investors and borrowers .

Transaction Fees, page 91

5. We note your reference on page 96 to increased weighted average transaction fee rates in 2016. Please revise future filings to disclose the weighted average transaction fee rate for each period presented and provide appropriate discussion and analysis of any significant changes or trends .

Consolidated Financial Statements

Note 15 – Commitments and contingencies , Contingencies, page F -42

6. We note your response to comment 14 and your proposed revised disclosure. Please note that the guidance in ASC 450 -20-50 specifically refers to reasonably possible losses. Accordingly, please clarify for us and revise your dis closure in future filings to clearly disclose:

 The amount or range of reasonably possible losses in addition to amounts accrued, or  That reasonably possible losses cannot be estimated, or  That any reasonable possible losses in addition to the amounts accr ued is not material to your financial statements.

Yu Cong Yirendai Ltd. September 28, 2017 Page 3

You may contact Benjamin Phippen, Staff Accountant at (202) 551 -3697 or me at (202) 551-3437 if you have questions regarding our comments.

Sincerely,
/s/ Michael Volley

Show Raw Text
Mail Stop 4720

September 28 , 2017

Yu Cong
Chief Financial Officer
Yirendai Ltd.
10/F, Building 9,91 Jianguo Road
Chaoyang District, Beijing 100022
The People’s Republic of China

Re: Yirendai Ltd.
Form 20 -F for the Fiscal Year Ended December 31, 2016
Filed  April 24, 2017
Response Dated September 1, 2017
  File No. 001 -37657

Dear Mr. Cong :

We have reviewed  your September 1, 2017 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 comments in our August 7,
2017 letter .

Form 20 -F for the Fiscal Year Ended December 31, 2016

Item 4. Information on the Company – Organizational Structure, page 77

1. Please revise the diagram illustrat ing your corporate structure and the discussion which
follows  in future filings to incorporate all of your consolidated entities, including the ABFEs
discussed on page F -10.

Item 5. Operating and Financial Review and Prospects, page 83

2. We note your response to comment 3 .  Please revise your disclosure of loans facilitated by
channel on page 54 and by grade on page 89 or similar disclosure in future filings to present

Yu Cong
Yirendai Ltd.
September 28, 2017
Page 2

 the percentage of the total amount of originations for each channel or grade.  Also, to the
extent change s or trends in originations by channel or grade result in an impact on your
origination volume and/or financial results, please provide appropriate  discussion and
analysis .

3. We note your response to comment 3.  To the extent changes or trends in maturit ies of your
loans result in an impact on your origination volume and/or financial results, please revise
future filings to p rovide appropriate discussion and analysis.

4. We note your response s and proposed disclosure  to comment s 4 and 5.  Please revise future
filings to provide a ppropriate discuss ion and analy sis of  any significant changes or trends  in
new investors and borrowers .

Transaction Fees, page 91

5. We note your reference on page 96 to increased weighted average transaction fee rates in
2016.  Please revise future filings to disclose the weighted average transaction fee rate for
each period presented and provide appropriate discussion and analysis  of any significant
changes or trends .

Consolidated Financial Statements

Note 15 – Commitments and contingencies , Contingencies, page F -42

6. We note your response to comment 14 and your proposed revised disclosure.  Please note
that the guidance in ASC 450 -20-50 specifically refers to reasonably possible losses.
Accordingly, please clarify for us and revise your dis closure in future filings to clearly
disclose:

 The amount or range of reasonably possible losses in addition to amounts accrued, or
 That reasonably possible losses cannot be estimated, or
 That any reasonable possible losses in addition to the amounts accr ued is not material
to your financial statements.

Yu Cong
Yirendai Ltd.
September 28, 2017
Page 3

 You may contact Benjamin Phippen, Staff Accountant  at (202) 551 -3697 or me at (202)
551-3437  if you have questions regarding our comments.

Sincerely,

 /s/ Michael Volley

Michael Volley
Staff  Accountant
Office of Financial Services