United States securities and exchange commission logo
December 21, 2021
Chad Bradford
Interim Chief Financial Officer
Elevate Credit, Inc.
4150 International Plaza, Suite 300
Fort Worth, Texas 76109
Re: Elevate Credit,
Inc.
Form 10-K filed
February 26, 2021
Form 10-Q filed
November 5, 2021
File No. 001-37680
Dear Mr. Bradford:
We have limited our review of your filings 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 fiscal year ended December 31, 2020
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 14 - Commitments, Contingencies and Guarantees, page 144
1. We note your disclosure
related to the materiality of your legal contingencies on page F-
144. In accordance with
ASC 450-20-50, please tell us, and revise future filings to
disclose, the following
information for your legal contingencies in the aggregate or
individually:
The amount or
range of reasonably possible losses in addition to amounts accrued; or
That reasonably
possible losses cannot be estimated; or
That any
reasonably possible losses in addition to the amounts accrued are not
material to your
financial statements.
Chad Bradford
Elevate Credit, Inc.
December 21, 2021
Page 2
Form 10-Q for the quarterly period ended September 30, 2021
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 4 - Variable Interest Entities, page 25
2. Please provide us with and revise future filings to disclose
quantitative information for
each VIE including revenue, gross profit and net income. Refer to
paragraphs 5A.d. and
2AA.d. of ASC 810-10-50 for guidance.
3. Please provide us with and revise future filings to include an
enhanced description of the
terms of the arrangements with each VIE, including how the credit
premium you receive
is calculated. Please also provide us with and enhance future filings
to better describe the
purpose for which each VIE was created from the perspective of both
the Company and
third-party investors. Refer to ASC 810-10-50-5A.d. for guidance.
4. Please tell us in detail why you do not recognize a non-controlling
interest related to the
ownership interests in the VIE. In future filings, please clearly
disclose which entity
receives the expected losses and expected residual returns.
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 Benjamin Phippen at (202) 551-3697 or Mike Volley at
(202) 551-3437
with any questions.
FirstName LastNameChad Bradford Sincerely,
Comapany NameElevate Credit, Inc.
Division of
Corporation Finance
December 21, 2021 Page 2 Office of
Finance
FirstName LastName