SEC Comment Letter 0000000000-22-013449 to Grab Holdings Ltd (GRAB, GRABW) (CIK 0001855612) (GRAB)
Grab Holdings Ltd (GRAB, GRABW) (CIK 0001855612)
Date: Dec. 14, 2022 · CIK: 0001855612 · Accession: 0000000000-22-013449
AI Filing Summary & Sentiment
File numbers found in text: 001-41110
Letter
United States securities and exchange commission logo December 14, 2022 Anthony Tan Ping Yeow Chairman and Chief Executive Officer Grab Holdings Limited 3 Media Close, #01-03/06 Singapore 138498 Re:Grab Holdings Limited Form 20-F for the Fiscal Year Ended December 31, 2021 Filed April 28, 2022 File No. 001-41110 Dear Anthony Tan Ping Yeow: We have reviewed your filing 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. Form 20-F for the Fiscal Year Ended December 31, 2021 Item 5. Operating and Financial Review and Prospects Results of Operations Comparison of the Years Ended December 31, 2021 and 2020, page 126 1.Please revise to separately quantify each material factor that contributed to the fluctuations in your results of operations. Refer to Item 5 of Form 20-F. Key Operating Metrics by Business Segment, page 138 2.We note your metric, Commission Rate, represents the dollar value paid in the form of commissions and fees from each transaction, without any adjustments for incentives paid to driver- and merchant-partners or promotions to end-users. As this measure excludes the impact of incentives, which are reductions to your revenue recorded under IFRS, it would appear that this measure represents a tailored recognition and measurement method. Please tell us how you considered Question 100.04 of the Compliance and
FirstName LastNameAnthony Tan Ping Yeow Comapany NameGrab Holdings Limited December 14, 2022 Page 2 FirstName LastName Anthony Tan Ping Yeow Grab Holdings Limited December 14, 2022 Page 2 Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G. 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. You may contact Keira Nakada at 202-551-3659 or Angela Lumey at 202-551-3398 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 14, 2022
Anthony Tan Ping Yeow
Chairman and Chief Executive Officer
Grab Holdings Limited
3 Media Close, #01-03/06
Singapore 138498
Re:Grab Holdings Limited
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 28, 2022
File No. 001-41110
Dear Anthony Tan Ping Yeow:
We have reviewed your filing 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.
Form 20-F for the Fiscal Year Ended December 31, 2021
Item 5. Operating and Financial Review and Prospects
Results of Operations
Comparison of the Years Ended December 31, 2021 and 2020, page 126
1.Please revise to separately quantify each material factor that contributed to the
fluctuations in your results of operations. Refer to Item 5 of Form 20-F.
Key Operating Metrics by Business Segment, page 138
2.We note your metric, Commission Rate, represents the dollar value paid in the form of
commissions and fees from each transaction, without any adjustments for incentives paid
to driver- and merchant-partners or promotions to end-users. As this measure excludes
the impact of incentives, which are reductions to your revenue recorded under IFRS, it
would appear that this measure represents a tailored recognition and measurement
method. Please tell us how you considered Question 100.04 of the Compliance and
FirstName LastNameAnthony Tan Ping Yeow
Comapany NameGrab Holdings Limited
December 14, 2022 Page 2
FirstName LastName
Anthony Tan Ping Yeow
Grab Holdings Limited
December 14, 2022
Page 2
Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of
Regulation G.
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.
You may contact Keira Nakada at 202-551-3659 or Angela Lumey at 202-551-3398 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services