October 17, 2019

Peter D'Arrigo
Chief Financial Officer
Envestnet, Inc.
35 East Wacker Drive, Suite 2400
Chicago, IL 60601

       Re: Envestnet, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Form 10-Q for Fiscal Quarter Ended June 30, 2019
           Filed March 1, 2019 and August 8, 2019
           File No. 001-34835

Dear Mr. D'Arrigo:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K filed March 1, 2019

Ityem 7. Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Business Segments, page 55

1.    Please tell us your consideration of the guidance in Question 104.04 of
the updated Non-
      GAAP Compliance and Disclosure Interpretations related to your
presentation of Total
      segment income from operations. Your current presentation of Total
segment income
      from operations for the years presented in any context other than the ASC
280 required
      reconciliation in the footnote appears to represent a non-GAAP financial
measure. Please
      note that this comment also applies to filings on Form 10-Q.
 Peter D'Arrigo
FirstName Inc.
Envestnet, LastNamePeter D'Arrigo
Comapany NameEnvestnet, Inc.
October 17, 2019
October 17, 2019 Page 2
Page 2
FirstName LastName
Non-GAAP Financial Measures, page 61

2.       Please tell us your consideration of the guidance in Question 100.04
of the Non-GAAP
         Compliance and Disclosure Interpretations related to your presentation
of Adjusted net
         income on page 64. In this regard, you used a tailored accounting
policy to normalize the
         effective tax rates used to compute Adjusted net income and Adjusted
net income per
         share. Please also tell us your consideration of Question 102.11 of
the Non-GAAP
         Compliance and Disclosure Interpretations related to your presentation
of income taxes
         and the income tax effects of non-GAAP adjustments in the
reconciliation of Adjusted net
         income on page 64. Please note that this comment also applies to
filings on Form 10-Q
         and press releases filed under Item 2.02 of Form 8-K.
Note 10 Other Non-Current Assets, page 100

3.       We note your disclosure on page 84 and 100 related to your use of the
cost method to
         account for investments. Please tell us your consideration of the
guidance in ASU 2016-
         01, Financial Instruments, and disclosure requirements in ASC
321-10-50-3 related
         to equity investments without readily determinable fair values.
Item 8. Financial Statements and Supplementary Data
12. Debt
Credit Agreement, page 104

4.       We note the Second Amended and Restated Credit Agreement includes
provisions that
         limit your ability and your subsidiaries to pay dividends. Please
describe the most
         significant restrictions on the payment of dividends by the
registrant, indicating their
         sources, their pertinent provisions, and the amount of retained
earnings or net income
         restricted or free of restrictions. Please also disclose the amount of
consolidated retained
         earnings which represents undistributed earnings of 50 percent or less
owned persons
         accounted for by the equity method. Please refer to Rule 4-08(e)(1)
and (2) of Regulation
         S-X. In addition, please tell us your consideration of Rule 4-08(e)(3)
of Regulation S-X
         which requires (1) disclosures about the nature and amount of
significant restrictions on
         the ability of subsidiaries to transfer funds to the parent through
intercompany loans,
         advances or cash dividends, and (2) the presentation of condensed
parent company
         financial information and other data in a schedule when the restricted
net assets of
         consolidated and unconsolidated subsidiaries, together with the
parent's equity in the
         undistributed earnings of 50%-or-less-owned entities, exceed 25% of
consolidated net
         assets as of the end of the most recently completed fiscal year.
Please refer to Rule 4-
         08(3) and Rule 12-04 of Regulation S-X.
Note 25. Quarterly Financial Data, page 121

5.       Please include net income (loss) in your tables in future filings.
Refer to Item 301(a)(1) of
         Regulation S-K.
 Peter D'Arrigo
Envestnet, Inc.
October 17, 2019
Page 3
Form 10-Q filed August 8, 2019

Non-GAAP Financial Measures, page 52

6.       Please tell us your consideration of the guidance in Question 100.04
of the Non-GAAP
         Compliance and Disclosure Interpretations related to your presentation
Adjusted revenues
         on page 52. In this regard, it appears the exclusion of the effect of
asset-based cost of
         revenue is a tailored revenue recognition and measurement method.
       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 Tony Watson at (202) 551-3318 or Bill Thompson at (202)
551-3344
with any questions.



FirstName LastNamePeter D'Arrigo                             Sincerely,
Comapany NameEnvestnet, Inc.
                                                             Division of
Corporation Finance
October 17, 2019 Page 3                                      Office of Trade &
Services
FirstName LastName