SEC Comment Letter for BILL Holdings, (BILL) — Nov 12, 2019
BILL Holdings, Inc.
Date: Nov. 12, 2019 · CIK: 0001786352 · Accession: 0000000000-19-015413
AI Filing Summary & Sentiment
Referenced dates: October 25, 2019
Letter
November 12, 2019 René Lacerte Chief Executive Officer Bill.com Holdings, Inc. 1810 Embarcadero Road Palo Alto, California 94303 Re:Bill.com Holdings, Inc. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted November 1, 2019 CIK 0001786352 Dear Mr. Lacerte: We have reviewed your amended draft registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Unless otherwise noted, where prior comments are referred to they refer to our letter dated October 25, 2019. Draft Registration Statement on Form S-1 Consolidated Financial Statements Consolidated Statements of Cash Flows, page F-8 1.We note your response to prior comment 2. Please revise to present the cash flows from the change in the customer fund deposits liability as a financing activity.
FirstName LastNameRené Lacerte Comapany NameBill.com Holdings, Inc. November 12, 2019 Page 2 FirstName LastName René Lacerte Bill.com Holdings, Inc. November 12, 2019 Page 2 You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587 or Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding comments on the financial statements and related matters. Please contact Jeff Kauten, Staff Attorney, at (202) 551-3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: James D. Evans, Esq.
Show Raw Text
November 12, 2019
René Lacerte
Chief Executive Officer
Bill.com Holdings, Inc.
1810 Embarcadero Road
Palo Alto, California 94303
Re:Bill.com Holdings, Inc.
Amendment No. 2 to Draft Registration Statement on Form S-1
Submitted November 1, 2019
CIK 0001786352
Dear Mr. Lacerte:
We have reviewed your amended draft registration statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless otherwise noted, where prior comments are referred to they refer to our letter
dated October 25, 2019.
Draft Registration Statement on Form S-1
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-8
1.We note your response to prior comment 2. Please revise to present the cash flows from
the change in the customer fund deposits liability as a financing activity.
FirstName LastNameRené Lacerte
Comapany NameBill.com Holdings, Inc.
November 12, 2019 Page 2
FirstName LastName
René Lacerte
Bill.com Holdings, Inc.
November 12, 2019
Page 2
You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587 or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding comments on
the financial statements and related matters. Please contact Jeff Kauten, Staff Attorney, at (202)
551-3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: James D. Evans, Esq.