HEALTHEQUITY, INC. (HQY) – Company response

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 →