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United States securities and exchange commission logo
April 9, 2021
Daniel G. Cohen
Chief Executive Officer
FinTech Acquisition Corp. IV
2929 Arch Street
Suite 1703
Philadelphia, PA 19104-2870
Re: FinTech Acquisition
Corp. IV
Amendment No. 1 to
Preliminary Proxy
Statement on Schedule 14A
Filed March 29,
2021
File No. 001-39558
Dear Mr. Cohen:
We have reviewed your March 29, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
March 4, 2021 letter.
Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A filed
March 29, 2021
Unaudited Pro Forma Condensed Combined Financial Information, page 108
1. We note from your
response to prior comment 8, the following two items:
You indicate that
issuance of equity interests to working partners of Professional
Partners will not
affect future distributions to Professional Partners, Perella Weinberg
Partners or the
remaining ILPs.
Under the guidance
in ASC 323-10-25-3 to 25-6, the other equity method investors
recognize their
percentage share of earnings or losses in the investee (inclusive of any
expense recognized
by the investee for the stock-based compensation funded on its
behalf).
Daniel G. Cohen
FinTech Acquisition Corp. IV
April 9, 2021
Page 2
Please reconcile for us your attribution methodology with these two
items. In this regard,
provide us an explanation of:
How an attribution methodology that is disproportionate to the
respective ownership
interests is appropriate absent a contractual arrangement that
affects distributions of
income or loss; and
How your attribution methodology is consistent with the guidance
in ASC 323-10-
25-3 to 25-6 when the other interest holders share of PWP OpCo
s net losses are
exclusive of any expense related to the equity awards granted by
Professional
Partners.
Unaudited Pro Forma Condensed Combined Statement of Financial Condition, page
108
2. Please explain to us why there is no apparent pro forma statement of
financial
condition impact for pro forma adjustments (cc) and (hh). Otherwise,
tell us how these
adjustments are reflected on your pro forma statement of financial
condition and revise
your disclosure to clarify. In addition, in your response tell us why
your pro forma net
loss attributable to Perella Weinberg Partners assuming no redemptions
of $34.3 million
in 2020 is inconsistent with the $27.1 million accumulated deficit on
your pro forma
statement of financial condition and reconcile for us the related
$108.6 million pro forma
loss attributable to noncontrolling interest and the $122.4 million
noncontrolling interest
on your pro forma statement of financial condition.
You may contact Mark Brunhofer at (202) 551-3638 or Michelle Miller at
(202) 551-
3368 if you have questions regarding comments on the financial statements and
related
matters. Please contact Eric Envall at (202) 551-3234 or J. Nolan McWilliams at
(202) 551-
3217 with any other questions.
FirstName LastNameDaniel G. Cohen Sincerely,
Comapany NameFinTech Acquisition Corp. IV
Division of
Corporation Finance
April 9, 2021 Page 2 Office of
Finance
FirstName LastName