United States securities and exchange commission logo
April 28, 2023
Steven Cunningham
Chief Financial Officer
Enova International, Inc.
175 West Jackson Blvd.
Chicago, IL 60604
Re: Enova
International, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2022
Filed February 24,
2023
File No. 001-35503
Dear Steven Cunningham:
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 filed February 24, 2023
Bank Programs, page 2
1. Please tell us and
revise future filings, here or in MD&A, to discuss the number of and
any significant
reliance on a particular bank partner and quantify the amount of revenue
earned and loans
purchased through your bank partner program for each period presented
and discuss any trends.
Please refer to Item 303(a) of Regulation S-K and SEC Release
No. 33-8350 for
guidance.
Our Markets, page 2
2. Please tell us and
revise future filings, here or in MD&A, to disclose any concentration of
originations by state.
Steven Cunningham
FirstName LastNameSteven Cunningham
Enova International, Inc.
Comapany
April NameEnova International, Inc.
28, 2023
April 228, 2023 Page 2
Page
FirstName LastName
Products and Services, page 2
3. Please tell us and revise future filings to provide additional
information for each
significant loan product to allow an investor to understand the nature
of your loan
products. At a minimum, discuss the estimated average contractual
term, the typical
payment structure (e.g. - regular payments that amortize the loan to
zero at maturity,
interest-only payments, a single payment at maturity, etc.), the
typical of fees or interest
charged (e.g. fixed interest rates, variable interest rates,
one-time fee based on the
principal amount, etc.), and the estimated annual percentage rate,
average yield earned or
average interest rate charged per loan. Please clarify if any
significant loan product
includes a single-pay structure and provide the key terms of this loan
product. Please
refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for
guidance.
Marketing, page 8
4. We note your disclosure that you have increased the percentage of
loans sourced through
direct marketing to 41% in 2022 and your disclosure on page 22 that
the success of your
business depends substantially on the willingness and ability of lead
providers or
marketing affiliates to provide you with customer leads at acceptable
prices. Please tell us
and revise future filings, here or in MD&A, to:
disclose the percentage of loans sourced through each of your
marketing channels for
each period presented and discuss any trends, and
discuss the number of and any significant reliance on a
particular marketing partner.
Please refer to Item 303(a) of Regulation S-K and SEC Release No.
33-8350 for guidance.
CFPB, page 13
5. We note your disclosure that you remain subject to restrictions and
obligations, including
a prohibition from engaging in certain conduct, related to a January
25, 2019 Consent
Order with the CFPB. Please tell us and revise future filings to
disclose each significant
provision under the terms of the Consent Order, the actions you have
taken or you plan to
take to comply with each provision and the current status of your
compliance.
Additionally, please discuss how your actions will impact future
financial results and
trends including credit quality trends and discuss what the steps
needed for the CFPB to
terminate the Consent Order.
Results of Operations, page 43
6. We note your disclosure on page 73 that revenue includes: interest
income, finance
charges, fees for services provided through the Company s CSO
programs, revenue on
RPAs, service charges, draw fees, minimum billing fees, purchase fees,
origination fees,
late fees and non-sufficient funds fees. Noting the different nature
the sources of revenue,
please tell us and revise future filings to separately disclose each
significant revenue
Steven Cunningham
FirstName LastNameSteven Cunningham
Enova International, Inc.
Comapany
April NameEnova International, Inc.
28, 2023
April 328, 2023 Page 3
Page
FirstName LastName
amount for each period presented and discuss any trends. Please refer
to Item 303(a) of
Regulation S-K and SEC Release No. 33-8350 for guidance.
Loan and Finance Receivable Balances, page 48
7. Please tell us and revise future filings to explain the relationship
between the average loan
and finance receivable origination amount in the table at the bottom
of page 49 and the
average amount outstanding per loan and finance receivable amount in
the table at the top
of page 49. Specifically describe why the origination amount is
significantly smaller than
the amount outstanding.
Consumer Loans and Finance Receivables, page 51
8. We note your discussion of the different revenue and credit
characteristics of line of credit
products here and in the small business loans section on page 54.
Please tell us and revise
future filings to disclose the information presented in the tables on
pages 51 -54 separately
for installment loans, lines of credit, and any other material loan
product. Please refer to
Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for
guidance.
9. We note your discussion related to the impact that the amount of
originations has on your
profitability and credit trends. Please tell us and revise future
filings to include the
amount of originations in the tables on pages 51-54 by loan product
and discuss any
trends. Please refer to Item 303(a) of Regulation S-K and SEC Release
No. 33-8350 for
guidance.
10. We note your discussion during your 2022 fourth quarter earnings
conference call that
originations from new customers during the quarter was 42% of total
originations and
your disclosure on page 52 that new customers typically have a higher
default rate than
returning customers. Please tell us and revise future filings to
quantify, for each period
presented, the dollar amount and percentage of originations by new
customer and
returning customers. To the extent there is a significant difference,
please clarify if
returning customers typically represent renewals of existing loans or
new loans.
11. We note your discussion on page 6 that if a loan is renewed or
refinanced, it is considered
a new loan. Please tell us and revise your disclosure of significant
accounting policies in
your financial statements in future filings to discuss how you
determine whether a renewal
is accounted for as a new loan or as a modification. Please tell us
the guidance you
considered in making your determination.
Current and Delinquent Loans and Finance Receivables, page 74
12. To the extent material, please tell us and revise future filings, here
or in MD&A, to
disclose the amount of payment deferrals in each period presented and
the impact on
financial results and trends.
Steven Cunningham
Enova International, Inc.
April 28, 2023
Page 4
Note 3. Loans and Finance Receivables, page 80
13. Please tell us and revise future filings to disclose the amount of
accrued interest and fees
included in the principal balances in the table on the bottom of page
80.
14. Please tell us and revise future filings to clarify if Originations
and acquisitions in the
rollforward on page 81 is presented on a cost basis or a fair value
basis.
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 William Schroeder at 202-551-3294 or Michael Volley at
202-551-
3437 with any questions.
FirstName LastNameSteven Cunningham Sincerely,
Comapany NameEnova International, Inc.
Division of
Corporation Finance
April 28, 2023 Page 4 Office of
Finance
FirstName LastName