SEC Comment Letter 0000000000-24-010692 to Dayforce, Inc. (DAY) (CIK 0001725057)
Dayforce, Inc. (DAY) (CIK 0001725057)
Date: Sept. 20, 2024 · CIK: 0001725057 · Accession: 0000000000-24-010692
AI Filing Summary & Sentiment
File numbers found in text: 001-38467
Letter
September 20, 2024 Jeremy R. Johnson Chief Financial Officer Dayforce, Inc. 3311 East Old Shakopee Road Minneapolis, Minnesota 55425 Re:Dayforce, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-38467 Dear Jeremy R. Johnson: We have reviewed your filing 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 the 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 the Fiscal Year Ended December 31, 2023 Item 11. Executive Compensation, page 98 1.From the disclosure incorporated by reference from page 39 of the Definitive Proxy Statement filed on March 12, 2024, it appears that you have not provided your disclosure about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a recovery analysis, please also include the interactive data. 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.
September 20, 2024 Page 2 Please contact Robert Arzonetti at 202-551-8819 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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September 20, 2024
Jeremy R. Johnson
Chief Financial Officer
Dayforce, Inc.
3311 East Old Shakopee Road
Minneapolis, Minnesota 55425
Re:Dayforce, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-38467
Dear Jeremy R. Johnson:
We have reviewed your filing 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 the
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 the Fiscal Year Ended December 31, 2023
Item 11. Executive Compensation, page 98
1.From the disclosure incorporated by reference from page 39 of the Definitive Proxy
Statement filed on March 12, 2024, it appears that you have not provided your disclosure
about your recovery analysis in an Interactive Data File in accordance with Rule 405 of
Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a
recovery analysis, please also include the interactive data.
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.
September 20, 2024
Page 2
Please contact Robert Arzonetti at 202-551-8819 or James Lopez at 202-551-3536 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance