SEC Comment Letter 0000000000-24-002080 to BILL Holdings, Inc. (BILL) (CIK 0001786352) (BILL)
BILL Holdings, Inc. (BILL) (CIK 0001786352)
Date: Feb. 23, 2024 · CIK: 0001786352 · Accession: 0000000000-24-002080
AI Filing Summary & Sentiment
File numbers found in text: 001-39149
Letter
United States securities and exchange commission logo February 23, 2024 John Rettig Chief Financial Officer Bill Holdings, Inc. 6220 America Center Drive, Suite 100 San Jose, CA 95002 Re:Bill Holdings, Inc. Form 10-K for the fiscal year ended June 30, 2023 Form 8-K furnished on August 17, 2023 Response dated February 16, 2024 File No. 001-39149 Dear John Rettig: We have reviewed your February 16, 2024 response to our comment letter and have the following comments. 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 a 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. Unless we note otherwise, any references to prior comments are to comments in our January 19, 2024 letter. Form 10-K for the fiscal year ended June 30, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Comparison of Fiscal 2023 and 2022, page 65 1.We note your response to prior comment 2. Please separately disclose the amount of subscription revenue versus transaction revenue in your MD&A. In this regard, your response indicates that you believe this information is useful to investors and provides insight into management’s perspective on the company’s business performance.
FirstName LastNameJohn Rettig Comapany NameBill Holdings, Inc. February 23, 2024 Page 2 FirstName LastName John Rettig Bill Holdings, Inc. February 23, 2024 Page 2 Form 8-K furnished on August 17, 2023 Exhibit 99.1 Reconciliation of net loss, page 13 2.We note your response to prior comment 4. Please revise to include a separate income tax adjustment commensurate with your non-GAAP measure of profit beginning with your next fiscal quarter and ensure that all prior periods are revised accordingly. Also, refrain from presenting "Current method of non-GAAP net income" as proposed in your response. Refer to Non-GAAP C&DI Question 102.11. Please contact Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Raj Aji
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United States securities and exchange commission logo
February 23, 2024
John Rettig
Chief Financial Officer
Bill Holdings, Inc.
6220 America Center Drive, Suite 100
San Jose, CA 95002
Re:Bill Holdings, Inc.
Form 10-K for the fiscal year ended June 30, 2023
Form 8-K furnished on August 17, 2023
Response dated February 16, 2024
File No. 001-39149
Dear John Rettig:
We have reviewed your February 16, 2024 response to our comment letter and have the
following comments.
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 a
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. Unless
we note otherwise, any references to prior comments are to comments in our January 19, 2024
letter.
Form 10-K for the fiscal year ended June 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Comparison of Fiscal 2023 and 2022, page 65
1.We note your response to prior comment 2. Please separately disclose the amount of
subscription revenue versus transaction revenue in your MD&A. In this regard, your
response indicates that you believe this information is useful to investors and provides
insight into management’s perspective on the company’s business performance.
FirstName LastNameJohn Rettig
Comapany NameBill Holdings, Inc.
February 23, 2024 Page 2
FirstName LastName
John Rettig
Bill Holdings, Inc.
February 23, 2024
Page 2
Form 8-K furnished on August 17, 2023
Exhibit 99.1
Reconciliation of net loss, page 13
2.We note your response to prior comment 4. Please revise to include a separate income tax
adjustment commensurate with your non-GAAP measure of profit beginning with your
next fiscal quarter and ensure that all prior periods are revised accordingly. Also, refrain
from presenting "Current method of non-GAAP net income" as proposed in your
response. Refer to Non-GAAP C&DI Question 102.11.
Please contact Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Raj Aji