United States securities and exchange commission logo
October 27, 2020
Jason Ream
Chief Financial Officer
Sailpoint Technologies Holdings, Inc.
11120 Four Points Drive
Suite 100
Austin, TX 78726
Re: Sailpoint
Technologies Holdings, Inc.
Form 10-K for the
Year Ended December 31, 2019
Form 10-Q for the
Period Ended June 30, 2020
File 001-38297
Dear Mr. Ream:
We have reviewed your filings 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-Q for the Period Ended June 30, 2020
Unaudited Condensed Consolidated Financial Statements
Revenue Recognition, page 8
1. Please tell us how you
considered further disaggregating subscription revenue into fees for
SaaS offerings and fees
for ongoing maintenance and support. We note that maintenance
contracts typically
have a one year term while your standard subscription agreement for
SaaS offerings has a
term of three years. We also note statements in your August 8, 2020
Form 8-K and earnings
call and which suggest that that you may separately identify SaaS
revenues for purposes
of evaluating financial performance and making resource allocation
decisions. For example,
in your August 6, 2020 Form 8-K, management states "our focus
is on investing in the
capabilities of our SaaS offerings and delivering against this market
opportunity." Please
refer to ASC 606-10-55-90.
Jason Ream
Sailpoint Technologies Holdings, Inc.
October 27, 2020
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Comparison of Three and Six Months Ended June 30, 2020 and 2019, page 27
2. In your August 8, 2020 earnings call, management indicated that
customer interest in your
SaaS platform continues to grow and that you expect a significant
portion of new business
to transition to SaaS over the coming quarters and years. In the
interest of providing
enhanced transparency for investors regarding trends affecting your
business, please
revise your discussion of subscription revenues in future filings to
separately quantify the
fluctuations attributable to changes in ongoing maintenance revenues
separate from SaaS
offerings. Please refer to Items 303(a)(3) and 303(b) of Regulation
S-X.
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 Lisa Etheredge, Senior Staff Accountant, at (202)
551-3424 or Robert
S. Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have
questions.
FirstName LastNameJason Ream Sincerely,
Comapany NameSailpoint Technologies Holdings, Inc.
Division of
Corporation Finance
October 27, 2020 Page 2 Office of
Technology
FirstName LastName