SEC Comment Letter for REGIS CORP (RGS) (CIK 0000716643) (RGS) — Apr 28, 2009
REGIS CORP (RGS) (CIK 0000716643)
Date: April 28, 2009 · CIK: 0000716643 · Accession: 0000000000-09-022342
AI Filing Summary & Sentiment
Reasoning
Referenced dates: March 3, 2009, March 31, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 April 27, 2009 Mr. Randy L. Pearce Chief Financial Officer Regis Corporation 7201 Metro Boulevard Edina, Minnesota 55439 Re: Regis Corporation Form 10-K for Fiscal Year Ended June 30, 2008 Filed August 29, 2008 Form 10-Q for Fiscal Quarter Ended December 31, 2008 File No. 1-12725
Dear Mr. Pearce: We have reviewed your supplemental response letter dated March 31, 2009 as well as your filing and have the following comments. As noted in our comment letter dated March 3, 2009, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Form 10-K for Fiscal Year Ended June 30, 2008
Note 3. Acquisitions, Investments in Affiliates and Loans, page 85
Investment in MY Style, page 91 1. We note your response to prior comment 8. Please address the following items: • Tell us your consideration of EITF 02-14 in determining that the application of the equity method based on the conversion feature associated with the notes was appropriate. • Tell us your consideration of EITF 96-19 in determining your accounting treatment of the New Exchangeable Notes which replaced the Original Exchangeable Notes on September 24, 2008. Explain for us why a reduced principal amount is now exchangeable for a greater equity ownership interest in MY Style Co., Ltd.
Mr. Randy L. Pearce Regis Corporation April 27, 2009 Page 2 Form 10-Q for Fiscal Quarter Ended December 31, 2008
Note 6. Acquisitions, Investment in and Losses to Affiliates, page 16 2. Please explain why the carrying value of several of your investments as of June 30, 2008, as listed at page 17, differs from the carrying value disclosed at page 89 in your Form 10-K for the year ended June 30, 2008.
* * * * Please respond to these comments through correspondence over EDGAR within 10 business days or tell us when you will provide us with a response. You may contact Melissa Hauber, Senior Staff Accountant, at (202) 551-3368 or Robert S. Littlepage, Jr., Accountant Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 with any other questions.
S i n c e r e l y , L a r r y S p i r g e l A s s i s t a n t D i r e c t o r
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
April 27, 2009
Mr. Randy L. Pearce Chief Financial Officer Regis Corporation 7201 Metro Boulevard Edina, Minnesota 55439
Re: Regis Corporation
Form 10-K for Fiscal Year Ended June 30, 2008
Filed August 29, 2008
Form 10-Q for Fiscal Quarter Ended December 31, 2008 File No. 1-12725
Dear Mr. Pearce:
We have reviewed your supplemental response letter dated March 31, 2009 as
well as your filing and have the following comments. As noted in our comment letter dated March 3, 2009, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Form 10-K for Fiscal Year Ended June 30, 2008
Note 3. Acquisitions, Investments in Affiliates and Loans, page 85
Investment in MY Style, page 91
1. We note your response to prior comment 8. Please address the following items:
• Tell us your consideration of EITF 02-14 in determining that the application
of the equity method based on the conversion feature associated with the notes was appropriate.
• Tell us your consideration of EITF 96-19 in determining your accounting treatment of the New Exchangeable Notes which replaced the Original Exchangeable Notes on September 24, 2008. Explain for us why a reduced principal amount is now exchangeable for a greater equity ownership interest in MY Style Co., Ltd.
Mr. Randy L. Pearce
Regis Corporation April 27, 2009 Page 2 Form 10-Q for Fiscal Quarter Ended December 31, 2008
Note 6. Acquisitions, Investment in and Losses to Affiliates, page 16
2. Please explain why the carrying value of several of your investments as of June
30, 2008, as listed at page 17, differs from the carrying value disclosed at page 89 in your Form 10-K for the year ended June 30, 2008.
* * * *
Please respond to these comments through correspondence over EDGAR within
10 business days or tell us when you will provide us with a response. You may contact Melissa Hauber, Senior Staff Accountant, at (202) 551-3368 or Robert S. Littlepage, Jr.,
Accountant Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 with any other questions.
S i n c e r e l y , L a r r y S p i r g e l A s s i s t a n t D i r e c t o r