TRINET GROUP, INC. (TNET) – Company response

Please tell us how you considered Question 100.03 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations when adjusting for interest expense while not adjusting for interest income in your non-GAAP measure, adjusted EBITDA. Background As a leading provider of HR solutions for SMBs in the U.S., one of the core services we offer is helping our clients manage their employee compensation by providing multi-state payroll processing. This involves holding and moving client funds intended for client payroll and related taxes. In 2024, we processed approximately $73 billion of…