United States securities and exchange commission logo
August 12, 2022
John Wagner
Chief Financial Officer
EverQuote, Inc.
210 Broadway
Cambridge, MA 02139
Re: EverQuote, Inc.
Form 10-K for the
fiscal year ended December 31, 2021
Filed February 25,
2022
Form 10-Q for the
quarterly period ended June 30, 2022
Filed August 4,
2022
File No. 001-38549
Dear Mr. Wagner:
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 fiscal year ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Key Business Metrics
Quote Requests, page 51
1. We note that quote
requests are consumer-initiated requests for an insurance quote that
result in a revenue
generating transaction. Please clarify what you mean by "result in a
revenue generating
transaction." In this regard, revise to disclose whether these include
all requests for an
insurance quote that you receive, whether it represents only requests
where you recognize
revenue or whether this only includes requests that are successfully
fulfilled by an
insurance provider.
John Wagner
FirstName
EverQuote,LastNameJohn Wagner
Inc.
Comapany
August 12, NameEverQuote,
2022 Inc.
August
Page 2 12, 2022 Page 2
FirstName LastName
Results of Operations, page 55
2. We note your discussion and presentation of Direct-to-Consumer-Agency
(DTCA)
operations throughout your earnings releases furnished on Form 8-K,
including year-over-
year DTCA revenue growth, policy growth and agent growth by quarter,
DTCA revenue
as a percentage of total revenue, and health-DTCA revenue. Please tell
us what
consideration was given to disclosing this information in your Form
10-K and Form 10-Q
filings. As part of your response, please tell us how you define your
DTCA
operations including the types of revenues included. Refer to Item
303(b) of Regulation
S-K and SEC Release No. 33-10751.
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page 76
3. We note you disclose revenue by distribution channel as that impacts
the nature and
amount of your revenue. Please revise to disclose what is meant by
direct distribution
channel versus indirect distribution channel, including identifying
who your customers are
in each case, and clarify how you account for revenues under each
channel. Ensure your
disclosure clearly addresses how the nature and amount of revenue
recorded varies under
each distribution channel.
Controls and Procedures, page 99
4. We note you originally identified your material weakness in internal
control over financial
reporting in your December 31, 2020 Form 10-K/A where you indicated
that management
intended to test your updated controls design during the fourth
quarter 2021. Accordingly,
please revise to address what steps have been completed in your
remediation plan to date,
including any completed control design and testing procedures, what
still remains to be
completed, and revise to update your estimate of the expected timing
of your remediation
plan.
Form 10-Q for the quarterly period ended June 30, 2022
Notes to Unaudited Condensed Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page 11
5. We note the long-term portion of your commissions receivable asset
increased 84%
between December 31, 2021 and June 30, 2022. Please explain to us why
there was such
a significant increase. Also, revise to disclose the typical payment
terms for your
commission revenue contracts. Refer to ASC 606-10-50-9.
John Wagner
FirstName
EverQuote,LastNameJohn Wagner
Inc.
Comapany
August 12, NameEverQuote,
2022 Inc.
August
Page 3 12, 2022 Page 3
FirstName LastName
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 Brittany Ebbertt, Senior Staff Accountant, at (202)
551-3572 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Technology