SEC Comment Letter 0000000000-23-005544 to Enfusion, Inc. (ENFN) (CIK 0001868912)
Enfusion, Inc. (ENFN) (CIK 0001868912)
Date: May 24, 2023 · CIK: 0001868912 · Accession: 0000000000-23-005544
AI Filing Summary & Sentiment
File numbers found in text: 001-40949
Letter
United States securities and exchange commission logo May 24, 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 reviewed your May 12, 2023 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 April 14, 2023 letter. Form 10-K for the Year Ended December 31, 2022 Note 11. Loss per Class A Common Share, page F-23 1.We note from your response prior comment 3, that you applied the guidance of ASC 260- 10-55-20(a) in determining the “adjustment to loss attributable to common stockholders.” Please tell us how you determined that the guidance in paragraph 55-20(a), which pertains to securities issued by a subsidiary that enables their holders to obtain the subsidiary’s common stock applies to your fact pattern. In this regard, we note your reference to the exchange of Enfusion Ltd LLC common units (i.e. subsidiary) for shares of Enfusion, Inc's (i.e. parent) common stock. Also, explain further your reference to attributing the net income or loss between controlling and noncontrolling interest and provide the calculations that support such adjustment.
FirstName LastNameBradley Herring Comapany NameEnfusion, Inc. May 24, 2023 Page 2 FirstName LastName Bradley Herring Enfusion, Inc. May 24, 2023 Page 2 Form 8-K furnished on March 7, 2023 Exhibit 99.1 2.Based on the information provided in your response to prior comment 4, the adjustment to your non-GAAP measure of adjusted free cash flow for “bonus timing and related employer taxes” appears to present a tailored accounting principle as you are assuming bonus payments are being made in the periods in which they are accrued and not when they are actually paid. Please refer to Question 100.04 of the non-GAAP C&DIs and revise to remove this adjustment. You may consider including the amount of bonus accrued or paid each period in a footnote to the non-GAAP reconciliation if you believe that information would be useful for investors. You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
May 24, 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 reviewed your May 12, 2023 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
April 14, 2023 letter.
Form 10-K for the Year Ended December 31, 2022
Note 11. Loss per Class A Common Share, page F-23
1.We note from your response prior comment 3, that you applied the guidance of ASC 260-
10-55-20(a) in determining the “adjustment to loss attributable to common stockholders.”
Please tell us how you determined that the guidance in paragraph 55-20(a), which pertains
to securities issued by a subsidiary that enables their holders to obtain the subsidiary’s
common stock applies to your fact pattern. In this regard, we note your reference to the
exchange of Enfusion Ltd LLC common units (i.e. subsidiary) for shares of Enfusion,
Inc's (i.e. parent) common stock. Also, explain further your reference to attributing the
net income or loss between controlling and noncontrolling interest and provide the
calculations that support such adjustment.
FirstName LastNameBradley Herring
Comapany NameEnfusion, Inc.
May 24, 2023 Page 2
FirstName LastName
Bradley Herring
Enfusion, Inc.
May 24, 2023
Page 2
Form 8-K furnished on March 7, 2023
Exhibit 99.1
2.Based on the information provided in your response to prior comment 4, the adjustment to
your non-GAAP measure of adjusted free cash flow for “bonus timing and related
employer taxes” appears to present a tailored accounting principle as you are assuming
bonus payments are being made in the periods in which they are accrued and not when
they are actually paid. Please refer to Question 100.04 of the non-GAAP C&DIs and
revise to remove this adjustment. You may consider including the amount of bonus
accrued or paid each period in a footnote to the non-GAAP reconciliation if you believe
that information would be useful for investors.
You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology