View:
United States securities and exchange commission logo
October 14, 2020
Timothy C. Oliver
Chief Financial Officer
NCR Corporation
864 Spring Street NW
Atlanta, GA 30308
Re: NCR Corporation
Form 10-K for the
Year Ended December 31, 2019
Filed February 28,
2020
Form 10-Q for the
Quarter Ended June 30, 2020
Filed July 31, 2020
File No. 001-00395
Dear Mr. Oliver:
We have limited our review of your filings 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 Year Ended December 31, 2019
Note 1. Basis of Presentation and Significant Accounting Polices
Revenue Recognition, page 56
1. You disclose that
revenue from term-based licenses is recognized at a point in time;
however, you also
indicate that term revenue is recognized for the committed term of the
contract, which is
typically one month to one year due to customer termination rights.
Please explain to us
this apparent inconsistency and revise your disclosures as necessary.
In this regard, tell us
whether revenue is recognized at a point in time or over time, during
the "committed term."
Further, tell us what the customer termination rights are, how they
impacted your
accounting for these arrangements, and the accounting guidance followed.
Lastly, tell us how
much revenue was recognized for term-based licenses for fiscal 2019
and to date in fiscal
2020. Please include proposed revised disclosures in your response.
Timothy C. Oliver
NCR Corporation
October 14, 2020
Page 2
2. Please describe for us the nature of your product solutions in which
you combine the
cloud-enabled SaaS and on-premise term-based software license as one
performance
obligation, and tell us how you considered ASC 606-10-25-21 in
accounting for these
arrangements. Also, tell us how much revenue was recognized from the
sale of such
solutions in fiscal 2019 and to date in fiscal 2020 and, to the extent
material, expand your
disclosures accordingly.
Form 10-Q for the Quarter Ended June 30, 2020
Note 16. Segment Information and Concentrations, page 41
3. You disclose that recurring revenue includes maintenance, cloud
revenue, and payments.
In the Form 8-K earnings release, furnished on July 28, 2020, you
state that "recurring
revenue means revenue from products and services for which revenue is
recognized over
time". Please tell us what specific revenue streams comprise recurring
revenue. Clarify
which products are recognized over time, consistent with your revenue
recognition policy,
and explain the nature of "payments." Lastly, revise your disclosures,
as necessary, and
include the proposed disclosures in your response.
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 Melissa
Kindelan, Senior Staff Accountant, at 202-551-3564 with any questions.
FirstName LastNameTimothy C. Oliver Sincerely,
Comapany NameNCR Corporation
Division of
Corporation Finance
October 14, 2020 Page 2 Office of
Technology
FirstName LastName