SEC Comment Letter for Afya Ltd (AFYA) (CIK 0001771007) (AFYA) — Oct 13, 2022
Afya Ltd (AFYA) (CIK 0001771007)
Date: Oct. 13, 2022 · CIK: 0001771007 · Accession: 0000000000-22-011286
AI Filing Summary & Sentiment
File numbers found in text: 001-38992
Letter
United States securities and exchange commission logo October 13, 2022 Virgilio Gibbon Chief Executive Officer Afya Limited Alameda Oscar Niemeyer , No. 119 Room 504 Vila da Serra Nova Lima Minas Gerais – MG, Brazil Re:Afya Limited Form 20-F for Fiscal Year Ended December 31, 2021 Filed April 29, 2022 File No. 001-38992 Dear Virgilio Gibbon: 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 20-F for Fiscal Year Ended December 31, 2021 Item 3. Key Information A. Selected Financial Data Operating Data, page 11 1.In the "Key Revenue Drivers" and "Key Operational Drivers" sections of your August 22, 2022 earnings release you provide more extensive operating data than disclosed in the "Operating Data" table in your annual report. To the extent this additional operating data is material to investors' understanding of your business, please consider revising to include the additional data. Item 5. Operating and Financial Review and Prospects A. Operating Results
FirstName LastNameVirgilio Gibbon Comapany NameAfya Limited October 13, 2022 Page 2 FirstName LastName Virgilio Gibbon Afya Limited October 13, 2022 Page 2 Historical Consolidated Results of Operations, page 109 2.Please revise to quantify factors to which changes are attributed. For example, you disclose the increase in revenue was primarily driven by: (i) organic revenue growth, mainly due to the maturation of medical school seats; (ii) consolidation of the results of operations of acquired companies in 2021 including two Mais Medicos campuses opened at the end of 2020, (iii) increase in the average ticket of Medical programs and, (iv) the fact that PEBMED has 12 months of net revenue in 2021, against approximately five months in 2020. Please also revise to discuss and analyze results of operations for each of your reportable segments. 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 Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
October 13, 2022
Virgilio Gibbon
Chief Executive Officer
Afya Limited
Alameda Oscar Niemeyer , No. 119
Room 504
Vila da Serra
Nova Lima Minas Gerais – MG, Brazil
Re:Afya Limited
Form 20-F for Fiscal Year Ended December 31, 2021
Filed April 29, 2022
File No. 001-38992
Dear Virgilio Gibbon:
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 20-F for Fiscal Year Ended December 31, 2021
Item 3. Key Information
A. Selected Financial Data
Operating Data, page 11
1.In the "Key Revenue Drivers" and "Key Operational Drivers" sections of your August 22,
2022 earnings release you provide more extensive operating data than disclosed in the
"Operating Data" table in your annual report. To the extent this additional operating data
is material to investors' understanding of your business, please consider revising to
include the additional data.
Item 5. Operating and Financial Review and Prospects
A. Operating Results
FirstName LastNameVirgilio Gibbon
Comapany NameAfya Limited
October 13, 2022 Page 2
FirstName LastName
Virgilio Gibbon
Afya Limited
October 13, 2022
Page 2
Historical Consolidated Results of Operations, page 109
2.Please revise to quantify factors to which changes are attributed. For example, you
disclose the increase in revenue was primarily driven by: (i) organic revenue growth,
mainly due to the maturation of medical school seats; (ii) consolidation of the results of
operations of acquired companies in 2021 including two Mais Medicos campuses opened
at the end of 2020, (iii) increase in the average ticket of Medical programs and, (iv) the
fact that PEBMED has 12 months of net revenue in 2021, against approximately five
months in 2020. Please also revise to discuss and analyze results of operations for each of
your reportable segments.
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 Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services