SEC Comment Letter for Shift4 Payments, Inc. (FOUR, FOUR-PA) (CIK 0001794669) (FOUR) — Jun 21, 2022
Shift4 Payments, Inc. (FOUR, FOUR-PA) (CIK 0001794669)
Date: June 21, 2022 · CIK: 0001794669 · Accession: 0000000000-22-006668
AI Filing Summary & Sentiment
File numbers found in text: 001-39313
Letter
United States securities and exchange commission logo June 21, 2022 Bradley Herring Chief Financial Officer Shift4 Payments, Inc. 2202 N. Irving Street Allentown, PA 18109 Re:Shift4 Payments, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Response date June 3, 2022 File No. 001-39313 Dear Mr. Herring: We have reviewed your June 3, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our May 11, 2022 letter. Form 10-K for the Fiscal Year Ended December 31, 2021 Consolidated Statements of Cash Flows, page 86 1.We note your response to comment one. Please explain in greater detail why you consider capitalized acquisition costs and residual commission buyouts to represent productive assets. Notes to Consolidated Financial Statements 9. Equipment for Lease, Net, page 109 2.We note your response to comment two, specifically that you considered ASC 840 and 842. However, your response did not address how you considered Rule 5-03.2 of Regulation S-X, as the equipment costs appear to relate directly to your products and services that generate revenue. Please explain. Additionally, we note you intend to
FirstName LastNameBradley Herring Comapany NameShift4 Payments, Inc. June 21, 2022 Page 2 FirstName LastName Bradley Herring Shift4 Payments, Inc. June 21, 2022 Page 2 comply with SAB 11.B by revising future filings to indicate on the face of the statement of operations parenthetically, that cost of sales excludes depreciation of equipment under lease and refer to the footnote. Please note under SAB Topic 11.B, depreciation and amortization may be excluded from cost of sales if the line item clearly discloses its exclusion "and" the income statement does not include gross profit. You may contact Scott Stringer at 202-551-32725 or Adam Phippen at 202-551-3336 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Jordan Frankel
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United States securities and exchange commission logo
June 21, 2022
Bradley Herring
Chief Financial Officer
Shift4 Payments, Inc.
2202 N. Irving Street
Allentown, PA 18109
Re:Shift4 Payments, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Response date June 3, 2022
File No. 001-39313
Dear Mr. Herring:
We have reviewed your June 3, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
May 11, 2022 letter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Consolidated Statements of Cash Flows, page 86
1.We note your response to comment one. Please explain in greater detail why you
consider capitalized acquisition costs and residual commission buyouts to represent
productive assets.
Notes to Consolidated Financial Statements
9. Equipment for Lease, Net, page 109
2.We note your response to comment two, specifically that you considered ASC 840 and
842. However, your response did not address how you considered Rule 5-03.2 of
Regulation S-X, as the equipment costs appear to relate directly to your products and
services that generate revenue. Please explain. Additionally, we note you intend to
FirstName LastNameBradley Herring
Comapany NameShift4 Payments, Inc.
June 21, 2022 Page 2
FirstName LastName
Bradley Herring
Shift4 Payments, Inc.
June 21, 2022
Page 2
comply with SAB 11.B by revising future filings to indicate on the face of the statement
of operations parenthetically, that cost of sales excludes depreciation of equipment under
lease and refer to the footnote. Please note under SAB Topic 11.B, depreciation and
amortization may be excluded from cost of sales if the line item clearly discloses its
exclusion "and" the income statement does not include gross profit.
You may contact Scott Stringer at 202-551-32725 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Jordan Frankel