United States securities and exchange commission logo
June 13, 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
Response Dated May
26, 2023
File No. 001-35503
Dear Steven Cunningham:
We have reviewed your May 26, 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 28, 2023 letter.
Form 10-K filed February 24, 2023
Bank Programs, page 2
1. Please refer to comment
1. Please confirm that you will revise future filings to quantify
the amounts of
purchases and revenue, if materially different, through your bank partner
program for each period
presented and discuss any trends.
Products and Services, page 2
2. Please tell us and
revise to disclose how you legally recognize loan interest income and
how your loans are
amortized. For example, disclose if you legally recognize interest
income on an
accelerated basis. If so, describe how the timing of loan renewals or
refinances during the
contractual term impact the amount of revenue recognized.
Steven Cunningham
Enova International, Inc.
June 13, 2023
Page 2
3. Please refer to comment 3. Noting the significant range of contractual
terms on
installment loans, please tell us and revise to disclose the estimated
average contractual
term.
Marketing, page 8
4. Please refer to comment 4. To the extent that a reliance on or changes
in a particular
marketing channel have a material impact on the quality of, and
potential variability of
your earnings and cash flow, please disclose information necessary for
investors to
ascertain the likelihood that past performance is indicative of future
performance.
Consumer Loans and Finance Receivables, page 51
5. Please refer to comment 8. Noting the impact of the line of credit
product on your
financial metrics and trends, please tell us and revise future filings
to separately present
the net revenue margin percentage for each material product in your
consumer and small
business portfolios tables on pages 51-54.
6. Please refer to comment 10. Please tell us and revise future filings
to quantify, for each
period presented, the dollar amount and percentage of originations by
customers
borrowing for the first time and returning customers. It appears this
information is
important for investors to better understand your business and your
underlying financial
metrics and trends. Please discuss how you define each group as
needed.
Note 3. Loans and Finance Receivables, page 80
7. Please refer to comment 13. Please provide us your proposed disclosure
using amounts as
of December 31, 2022.
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
June 13, 2023 Page 2 Office of
Finance
FirstName LastName