SEC Comment Letter 0000000000-23-003734 to Enfusion, Inc. (ENFN) (CIK 0001868912)
Enfusion, Inc. (ENFN) (CIK 0001868912)
Date: April 14, 2023 · CIK: 0001868912 · Accession: 0000000000-23-003734
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File numbers found in text: 001-40949
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United States securities and exchange commission logo
April 14, 2023
Bradley Herring
Chief Financial Officer
Enfusion, Inc.
125 South Clark Street, Suite 750
Chicago, IL 60603
Re:Enfusion, Inc.
Form 10-K for the Year Ended December 31, 2022
Filed March 10, 2023
Form 8-K furnished on March 7, 2023
File No. 001-40949
Dear Bradley Herring:
We have limited our review of your filing to the financial statements and related
disclosures 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 10-K for the Year Ended December 31, 2022
Note 3. Summary of Significant Accounting Policies
Revenue Recognition
Service contract with multiple performance obligations, page F-12
1.Please tell us what is meant by your reference here to "highly specialized knowledge
required to execute on our solution." Also, tell us you how you considered the guidance
in ASC 606-10-25-21 in determining that implementation services are not separately
identifiable within the context of the contract. In your response, provide us with the
amount of implementation services for each period presented.
FirstName LastNameBradley Herring
Comapany NameEnfusion, Inc.
April 14, 2023 Page 2
FirstName LastName
Bradley Herring
Enfusion, Inc.
April 14, 2023
Page 2
Remaining Performance Obligations, page F-12
2.We note that you expect to recognize the remaining performance obligations over the next
one to five years. Please revise to disclose when you expect to recognize such amounts as
revenue on a quantitative basis using time bands that would be most appropriate for the
duration of the remaining performance obligations or by providing qualitative
information. Refer to ASC 606-10-50-13.
Note 11. Loss per Class A Common Share, page F-23
3.Your presentation of net loss per share of Class A common stock includes an “adjustment
to loss attributable to common stockholders” for both periods. Please describe for us the
nature of this adjustment as well as the authoritative accounting guidance that you relied
upon.
Form 8-K Furnished on March 7, 2023
Exhibit 99.1, page 19
4.Please tell us what the adjustment for "bonus timing and non-recurring expenses" included
in the adjusted free cash flow measure represents. In this regard, tell us whether the bonus
adjustment relates to cash bonuses or share-based compensation and what portion of the
bonus is included in the adjustment (i.e. the amortized portion or the remaining
unamortized balance). Also, provide us with a breakdown of the non-recurring or unusual
items for each period presented. Lastly, explain what this measure is intended to convey.
In closing, 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 David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology