HEALTHEQUITY, INC. (HQY) – SEC staff letter
2026-01-27 · Re: Form 10-K for Fiscal Year Ended January 31, 2025 · Accession 0000000000-26-000925 · 2 staff comment(s) issued
Company response(s): 2026-01-29
Non-GAAP: Equal ProminenceNon-GAAP: Reconciliation & UsefulnessKPIs, Metrics & Earnings Calls
2026-01-27 · Form 10-K for Fiscal Year Ended January 31, 2025 · Comment 1 · Key financial and operating metrics, page 35 Responded
Staff comment: We note that you present a discussion of non-GAAP measures prior to your discussion of GAAP results. Please revise to present the discussion and analysis of your GAAP measures with equal or greater prominence than your non-GAAP discussion. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and the guidance in Question 102.10(a) of the Non- GAAP Financial Measures Compliance and Disclosure Interpretations.
letter → Company response: to this comment, commencing with our FY 2026 Form 10-K, we will move the sections entitled “Adjusted EBITDA” and “Non-GAAP net income,” which include a discussion of non-GAAP financial measures, from their current location to a new section to be captioned “Non-GAAP financial measures” that follows the “Results of operations” section, which contains a discussion of our GAAP results, so that our discussion and analysis of our GAAP measures have equal or greater prominence than our non-GAAP discussion. Our existing section titled “Key financial and operating metrics” will accordingly be renamed “Key operating metrics” to reflect the removal of these sections, as the sections “Adjusted EBITDA”…
response letter → 2026-01-27 · Form 10-K for Fiscal Year Ended January 31, 2025 · Comment 2 · of the Non- GAAP Financial Measures Compliance and Disclosure Interpretations. Awaiting / response not in dataset
Staff comment: We note that the reconciliation of net income to non-GAAP net income includes an adjustment for amortization of acquired intangible assets. Please disclose the nature of the amortization being excluded from the measure, and clarify that while the expense is excluded, the revenue of the acquired company is reflected in the measure and that the purchased intangible assets contribute to revenue generation.
letter → Full letter on EDGAR → · Filing index · All HEALTHEQUITY, INC. (HQY) correspondence
Non-GAAP: Equal Prominence – what to check: In earnings releases and MD&A, present the GAAP measure first and with at least equal emphasis, including headlines, bullets and tables.
Non-GAAP: Reconciliation & Usefulness – what to check: Reconcile every non-GAAP measure (including segment-level measures presented outside the ASC 280 note) to the most directly comparable GAAP measure, and explain why it is useful.
KPIs, Metrics & Earnings Calls – what to check:
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