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United States securities and exchange commission logo
August 18, 2021
Kenneth Tuchman
Chief Executive Officer
TTEC Holdings, Inc.
9197 South Peoria Street
Englewood, Colorado 80112
Re: TTEC Holdings, Inc.
Form 10-K for the
Year Ended December 31, 2020
Filed March 1, 2021
Form 8-K filed
August 4, 2021
File No. 001-11919
Dear Mr. Tuchman:
We have reviewed your filing 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, 2020
TTEC Holdings, Inc. and Subsidiaries Consolidated Financial Statements
Notes to the Consolidated Financial Statements
(2) Acquisitions, page F-17
1. Your disclosure in Note
2 indicates that you recognized redeemable non-controlling
interests at fair value
using Level 3 inputs in connection with the acquisitions of
Serendebyte and First
Call Resolution, LLC during 2020 and 2019. We also note that
these non-controlling
interests are potentially redeemable between January 31, 2023 and
December 31, 2023 at a
multiple of each acquired entity's trailing twelve month
EBITDA. Given this
factor, please revise to explain how you plan to account for potential
changes in the
redemption value of these redeemable non-controlling interests in your
financial statements.
Refer to the guidance in paragraph 15 of ASC 480-10-S99-3A.
Kenneth Tuchman
TTEC Holdings, Inc.
August 18, 2021
Page 2
Report on Form 8-K filed August 4, 2021
Exhibit 99.1
Business Outlook, page 3
2. In your press release furnished as Exhibit 99.1 to your report on Form
8-K, you provide
2021 Non-GAAP outlook information including Non-GAAP Operating Income
margins,
Non-GAAP Adjusted EBITDA margins and Non-GAAP earnings per share
amounts
without providing equally prominent disclosure of the related GAAP
measures or a
reconciliation of the Non-GAAP measures to the most comparable GAAP
measures.
Please revise your press releases to include disclosure of the most
comparable GAAP
measures on a 2021 outlook basis along with reconciliations of the
Non-GAAP measures
to the most comparable GAAP measures. Refer to the guidance in
Regulation G and
Question 102.10 of the Compliance and Disclosure Interpretations
Regarding Non-GAAP
Measures.
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 Blaise Rhodes at 202-551-3774 or Linda Cvrkel at
202-551-3813 if you
have questions.
FirstName LastNameKenneth Tuchman Sincerely,
Comapany NameTTEC Holdings, Inc.
Division of
Corporation Finance
August 18, 2021 Page 2 Office of Trade &
Services
FirstName LastName