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UPLOAD Filing

MeridianLink, Inc. (CIK 0001834494)
Date: Sept. 9, 2025 · CIK: 0001834494 · Accession: 0000000000-25-009718

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File numbers found in text: 001-40680

Date
September 9, 2025
Author
Division of
Form
UPLOAD
Company
MeridianLink, Inc. (CIK 0001834494)

Letter

Re: MeridianLink, Inc. Form 10-K for the Year Ended December 31, 2024 Response dated September 4, 2025 File No. 001-40680 Dear Elias Olmeta:

September 9, 2025

Elias Olmeta Chief Financial Officer MeridianLink, Inc. 1 Venture, Suite 235 Irvine, CA 92618

We have reviewed your September 4, 2025 response to our comment letter 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 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 August 20, 2025 letter.

Form 10-K for the year ended December 31, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 52

1. We note your response to prior comment 1. Please address the following: Explain further how you evaluate whether you have offsetting trends in your customer base. In this regard, explain how tracking revenue growth overall indicates whether you had any existing customer loss or contraction that was, potentially, offset by new customer growth, or vice versa. Tell us whether the lack of configuration between data feeds in your systems is related to the contract database issue that contributed to your material weakness in internal control. If so, clarify whether you expect that the ability to track new versus existing customer revenue trends will be remediated with the remediation of your material weakness. September 9, 2025 Page 2

Revise future filings to explain the basis for your qualitative assertions that the majority of the revenue growth was attributable to cross-selling to existing customer. In this regard, discuss the information as provided in your response that approximately 2,000 commercial financial institution customers generated most of your period over period increase in lending revenue. Also, discuss any limitations on your ability to provide quantitative information to support the source of your revenue growth.

Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at 202-551-3499 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Kayla Dailey

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 9, 2025

Elias Olmeta
Chief Financial Officer
MeridianLink, Inc.
1 Venture, Suite 235
Irvine, CA 92618

 Re: MeridianLink, Inc.
 Form 10-K for the Year Ended December 31, 2024
 Response dated September 4, 2025
 File No. 001-40680
Dear Elias Olmeta:

 We have reviewed your September 4, 2025 response to our comment letter
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 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 August
20, 2025 letter.

Form 10-K for the year ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 52

1. We note your response to prior comment 1. Please address the following:
 Explain further how you evaluate whether you have offsetting trends
in your
 customer base. In this regard, explain how tracking revenue growth
overall
 indicates whether you had any existing customer loss or contraction
that was,
 potentially, offset by new customer growth, or vice versa.
 Tell us whether the lack of configuration between data feeds in your
systems is
 related to the contract database issue that contributed to your
material weakness in
 internal control. If so, clarify whether you expect that the ability
to track new
 versus existing customer revenue trends will be remediated with the
remediation
 of your material weakness.
 September 9, 2025
Page 2

 Revise future filings to explain the basis for your qualitative
assertions that the
 majority of the revenue growth was attributable to cross-selling to
existing
 customer. In this regard, discuss the information as provided in
your response that
 approximately 2,000 commercial financial institution customers
generated most of
 your period over period increase in lending revenue. Also, discuss
any limitations
 on your ability to provide quantitative information to support the
source of your
 revenue growth.

 Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at
202-551-3499
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Kayla Dailey
</TEXT>
</DOCUMENT>