View:
United States securities and exchange commission logo
December 9, 2022
Michael Normile
Executive Vice President and Chief Financial Officer
Cass Information Systems, Inc.
12444 Powerscourt Drive, Suite 550
St. Louis, MO 63131
Re: Cass Information
Systems, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed February 28,
2022
File No. 000-20827
Dear Michael Normile:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we ask you
to provide us with
information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Liquidity, page 32
1. In regard to your net
cash flows provided by operating activities for the years presented,
you disclose net income
plus depreciation and amortization accounts for most of the
operating cash
provided. However, it is not clear how the sum of these amounts for each
year correlate to the
reported amounts of operating cash flows for the like year and
changes therein from
period to period. For example, the indicated sum, using amounts
reported in the
operating activities of the statement of cash flows, for 2021 and 2020
appears to be
$41,104(000) and $36,445(000), respectively, while reported operating cash
flows for 2021 and 2020
are $34,547(000) and $47,781(000), respectively. Your analysis
should discuss factors
that affected the reported amount of operating cash flow from
period to period and
the reasons underlying these factors. Note that references to results
and noncash items may
not provide a sufficient basis to understand how operating cash
Michael Normile
Cass Information Systems, Inc.
December 9, 2022
Page 2
actually was affected between periods. Refer to Item 303(b) of
Regulation S-K, the
introductory paragraph of section IV.B and paragraph B.1 of Release
No. 33-8350 for
guidance, and section 501.04 of our Codification of Financial
Reporting Releases
regarding quantification of variance factors. Please revise your
disclosure to discuss the
material factors that impacted operating cash flow from period to
period.
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 Patrick Kuhn at (202) 551-3308 or Doug Jones at (202)
551-3309 with
any questions.
FirstName LastNameMichael Normile Sincerely,
Comapany NameCass Information Systems, Inc.
Division of
Corporation Finance
December 9, 2022 Page 2 Office of Trade
& Services
FirstName LastName