View:
United States securities and exchange commission logo
August 4, 2021
Matthew Oppenheimer
Chief Executive Officer
Remitly Global, Inc.
1111 Third Avenue, Suite 2100
Seattle, WA 98101
Re: Remitly Global,
Inc.
Amendment No. 1 to
Draft Registration
Statement on Form S-1
Submitted July 21,
2021
CIK No. 0001782170
Dear Mr. Oppenheimer:
We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
We Benefit from a Powerful Flywheel, page 7
1. We note your response
to our prior comment 4 and reissue. In an appropriate place in
your registration
statement, disclose the underlying calculations that support your five-
year LTV/CAC ratio of
over 5x or, alternatively, please delete all references to the ratio.
We transfer large sums of customer funds daily, page 24
2. We note your response
to our prior comment 7 and reissue in part. We note your
disclosure that you
have experienced transaction losses of 0.11% and 0.14% of total send
volume in connection
with such errors, fraud, and misconduct in 2019 and 2020,
Matthew Oppenheimer
Remitly Global, Inc.
August 4, 2021
Page 2
respectively. Please revise to more directly tie these transaction
losses to your financial
statements and quantify the respective amounts as included within such
financial
statements.
A substantial amount of our revenue is derived from remittances to India, the
Philippines and
Mexico, page 45
3. We note your response to our prior comment 9 and reissue in part. We
note your
disclosure that your revenue has been substantially derived from
remittances to India, the
Philippines and Mexico and that remittances sent to these three
countries represented
approximately 75% of your revenue and send volume in the year ended
December 31,
2020. We also note that the remittance percentage to these three
countries have been
aggregated. With a review to revised disclosure, please advise if one
geographic location
represents a material portion of the 75% remittance percentage.
Principal Stockholders, page 156
4. We note your response to our prior comment 14 and reissue. Please
refer to footnote
(10). Please revise to disclose the natural person or persons who have
voting or
investment power with respect to the common stock listed in the table.
In this regard,
please name the members of the management committee.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Disbursement Prefunding, page F-11
5. We note your response and related revision to comment 17. Please tell
us how you
determined that disbursement prefunding amounts should be recognized
as an asset if you
do not have legal title to and ownership of such prefunded amounts.
Customer Support and Operations, page F-15
6. We note your response to comment 18. Please revise the filing to
disclose the detailed
description of activities/duties performed by your customer service
teams that was
included in your response.
General and Administrative, page F-15
7. We note your response and related revisions to comment 19, and we
reissue our comment
in part. Please tell us why you do not appear to allocate any
depreciation and/or
FirstName LastNameMatthew Oppenheimer
amortization expenses to transaction expenses, customer support and
operations, and/or
Comapany NameRemitly
technology Global, Inc.
and development expenses, when presumably some of the
underlying assets
Augustare used in
4, 2021 these
Page 2 respective functions.
FirstName LastName
Matthew Oppenheimer
FirstName LastNameMatthew Oppenheimer
Remitly Global, Inc.
Comapany
August NameRemitly Global, Inc.
4, 2021
August
Page 3 4, 2021 Page 3
FirstName LastName
Technology and Development, page F-15
8. We note your response and related revisions to comment 18. Please
address the following:
Whether research and development costs, as defined in ASC
730-10-55-1, are
quantitatively material, and if so, why research and development
costs are not
material from a qualitative perspective given that true research
and development costs
have some future benefit not characteristic of a typical expense;
and
Whether you are able to reasonably identify or estimate
research and development
costs. If you are unable to identify or estimate research and
development costs, please
explain in detail the reasons for your inability.
You may contact Stephen Kim at 202-551-3291 or Rufus Decker at
202-551-3769 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Donald Field at 202-551-3680 or Mara Ransom at 202-551-3264 with any
other
questions.
Sincerely,
Division of
Corporation Finance
Office of Trade
& Services