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Mail Stop 3561 August 21, 2018
Mr. Charles D. Drucker
Executive Chairman and Co-Chief Executive Officer
8500 Governor's Hill Drive
Symmes Township, OH 45249
Re: Worldpay, Inc.
Form 10-K for Fiscal Year Ended December 31, 2017
Filed February 28, 2018
Form 10-Q for Fiscal Quarter Ended June 30, 2018
Filed August 9, 2018
File No. 001-35462
Dear Mr. Drucker:
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-Q for Fiscal Quarter Ended June 30, 2018
Note 11. Segment Information, page 35
1. We note your disclosure that as a result of your acquisition of Legacy
Worldpay, you
reorganized your reportable segments. We further note that your
reportable segments are
the same as your operating segments. In order to assist us in
understanding your revised
segment presentation, please provide us with the following information:
Tell us the title and describe the role of each of the individuals
who report to the
CODM.
Identify and describe the role of each of your segment managers.
Mr. Charles D. Drucker
Worldpay, Inc.
August 21, 2018
Page 2
Tell us how often the CODM meets with his direct reports, the
financial information
the CODM reviews to prepare for those meetings, the financial
information discussed
in those meetings, and who else attends those meetings.
Tell us who is held accountable for each of your Worldpay US,
Worldpay UK and
Global eCommerce businesses and specific GAAP or non-GAAP financial
metrics
for which this person is held accountable (e.g. revenue, gross
profit). Also tell us the
title and role of the person this individual reports to in the
organization.
Describe the information regularly provided to the CODM and how
frequently it is
prepared.
Describe the information regularly provided to the Board of
Directors and how
frequently it is prepared.
Explain how budgets are prepared, who approves the budget at each
step of the
process, the level of detail discussed at each step, and the level
at which the CODM
makes changes to the budget.
Describe the level of detail communicated to the CODM when actual
results differ
from budgets and who is involved in meetings with the CODM to
discuss budget-to-
actual variances.
Describe the basis for determining the compensation for each of the
individuals that
report to the CODM, including the extent to which any such
individuals are
compensated based on the financial results of the Worldpay US,
Worldpay UK or
Global eCommerce businesses.
2. In light of the material change in your total assets arising from the
acquisition, in future
interim filings, please disclose segment assets. Refer to ASC
280-10-50-32(d).
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.
Mr. Charles D. Drucker
Worldpay, Inc.
August 21, 2018
Page 3
You may contact Sondra Snyder, Staff Accountant at (202) 551-3332, or me
at (202)
551-3737 with any questions.
Sincerely,
/s/ Jennifer Thompson
Jennifer Thompson
Accounting Branch Chief
Office of Consumer
Products