United States securities and exchange commission logo

                             October 14, 2021

       Ryan Schaffer
       Chief Financial Officer
       Expensify, Inc.
       401 SW 5th Ave
       Portland, Oregon 97204

                                                        Re: Expensify, Inc.
                                                            Amendment No. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted September
24, 2021
                                                            CIK No. 0001476840

       Dear Mr. Schaffer:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

               After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       July 1, 2021 letter.

       Amendment No. 2 to Draft Registration Statement on Form S-1

       Management's Discussion and Analysis
       Non-GAAP financial measures, page 85

   1.                                                   In order to avoid
giving undue prominence to Adjusted EBITDA and Adjusted EBITDA
                                                        margin, please revise
to move the discussion of these measures until after your analysis of
                                                        GAAP results of
operations. Please refer to Question 102.10 of the C&DI on Non-GAAP
                                                        Financial Measures.
 Ryan Schaffer
Expensify, LastNameRyan Schaffer
October 14,NameExpensify,
            2021          Inc.
Page 2 14, 2021 Page 2
FirstName LastName
Comparison of the six months ended June 30, 2020 and 2021, page 89

2.       We note several instances where the amounts presented in MD&A are
inconsistent with
         the amounts presented in the audited financial statements. For
example, in all periods
         presented, expenses presented in the tables on pages 90-92 are not
consistent with the line
         items reported on the Consolidated Statements of Income on page F-4.
We also note that
         the amount of stock based compensation presented in your Non-GAAP
reconciliation on
         page 79 for the year ended December 31, 2019 is not consistent with
the amount reported
         on page F-7.
3.       We note under Subsequent events that in July 2021, the company
determined that it would
         pay a cash bonus to each of its employees in a value that approximates
the cost of each
         employee exercising 45% of their total outstanding shares. We further
note that through
         September 24, 2021, you paid nearly $9.5 million in cash bonuses to
employees. Please
         revise your MD&A to disclose this obligation, including its
anticipated impact on your
         future cash flows and operating expenses for the foreseeable future.
Please also revise
         your disclosure on page F-21 to disclose the total amount of remaining
cash bonuses, if
         any, that you reasonably expect to pay subsequent to September 24,
2021. Please refer to
         Item 303 of Regulation S-K and ASC 855-10-50-2.
Consolidated Financial Statements
Note 9 - Stock-Based Compensation, page F-29

4.       Please provide us with a breakdown of the details of all stock-based
compensation awards
         granted since June 30, 2020, including the fair value of the
underlying stock used to value
         such awards. To the extent there were any significant fluctuations in
the fair values, please
         describe for us the factors that contributed to such fluctuations,
including any intervening
         events within the company or changes in your valuation assumptions or
        You may contact Lisa Etheredge, Senior Staff Accountant, at (202)
551-3424 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
comments on the financial statements and related matters. Please contact
Alexandra Barone,
Staff Attorney, at (202) 551-8816 or Jeff Kauten, Staff Attorney, at (202)
551-3447 with any
other questions.


                                                               Division of
Corporation Finance
                                                               Office of
cc:      Alexa Berlin