SEC Comment Letter 0000000000-24-010690 to Katapult Holdings, Inc. (KPLT)
Katapult Holdings, Inc.
Date: Sept. 20, 2024 · CIK: 0001785424 · Accession: 0000000000-24-010690
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-39116
Letter
September 20, 2024 Nancy Walsh Chief Financial Officer Katapult Holdings, Inc. 5360 Legacy Drive, Building 2 Plano, TX 75024 Re:Katapult Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-39116 Dear Nancy Walsh: 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 108 1.We note reference to your “Proxy Statement for the 2024 Annual Meeting of Stockholders,” filed on April 26, 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 questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Nicole Brookshire
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September 20, 2024
Nancy Walsh
Chief Financial Officer
Katapult Holdings, Inc.
5360 Legacy Drive, Building 2
Plano, TX 75024
Re:Katapult Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-39116
Dear Nancy Walsh:
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 108
1.We note reference to your “Proxy Statement for the 2024 Annual Meeting of
Stockholders,” filed on April 26, 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 questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Nicole Brookshire