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SEC Comment Letter for REGIS CORP (RGS) (CIK 0000716643) (RGS) — Apr 3, 2014

REGIS CORP (RGS) (CIK 0000716643)
Date: April 3, 2014 · CIK: 0000716643 · Accession: 0000000000-14-016858

Financial Reporting Regulatory Compliance Business Model Clarity

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Reasoning

Referenced dates: March 17, 2014

Date
April 3, 2014
Author
Jill Davis
Form
UPLOAD
Company
REGIS CORP (RGS) (CIK 0000716643)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4546

DIVISION OF CORPORATION FINANCE

April 3, 2014

Mr. Steven M. Spiegel Chief Financial Officer Regis Corporation 7201 Metro Blvd Minneapolis, MN 55439 Re: Regis Corporation File No. 001- 12725 Dear Mr. Spiegel ,

In your letter dated March 17, 2014, you request , on behalf of Regis Corporation (the Company), that the staff grant relief of the requirement to include in the Company’s 2013 Form 10- K the separate financial statements that are required by Rule 3 -09 of Regulation S -X for Provalliance. We understand that your investment in Provalliance was sold on September 27, 2012. We understand, based on the facts outlined in your letter , you have determined that audited financial statements for Provalliance are required to be included in the Company’s 2013 Form 10- K under Rule 3- 09 of R egulation S -X as at and for the period ended September 27, 2012.

Based on the Company’s unique facts and circumstances , as outlined in your letter , we will not object to its omission of the separate audited financial statements of Provalliance for the period ended September 27, 2012 and the unaudited financial statements of Provalliance for the years ended December 31, 2011 and 2010 from the Company’s 2013 Form 10- K.

The staff’s conclusion is based solely on the information included in your letter s. Different or additional material information could lead to a different conclusion. If you have any questions regarding this letter, please call me at (202) 551- 3683

Sincerely,
Jill Davis
Associate Chief Accountant

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4546

       DIVISION OF
CORPORATION FINANCE

      April 3, 2014

Mr. Steven M. Spiegel
Chief Financial Officer
Regis Corporation 7201 Metro Blvd
Minneapolis, MN 55439  Re: Regis Corporation
 File No. 001- 12725
 Dear Mr.  Spiegel ,

In your letter dated March 17, 2014, you request , on behalf of  Regis Corporation
(the Company), that the staff grant relief  of the requirement to include in the Company’s
2013 Form 10- K the separate financial statements that are required by Rule 3 -09 of
Regulation S -X for Provalliance.  We understand that your investment in Provalliance
was sold on September 27, 2012. We understand, based on the facts outlined in your letter , you have determined that audited financial  statements for Provalliance are required
to be included in the Company’s 2013 Form 10- K under Rule 3- 09 of R egulation S -X as
at and for the period ended September 27, 2012.

Based on the  Company’s  unique facts and circumstances , as outlined in your
letter , we will not object to its  omission of the separate audited financial statements of
Provalliance for the period ended September 27, 2012 and the unaudited financial
statements of Provalliance for the years ended December 31, 2011 and 2010 from the Company’s 2013 Form 10- K.

 The staff’s conclusion is based solely on the information included in your letter s.
Different or additional material information could lead to a different conclusion.  If you
have any questions regarding this letter, please call me at (202) 551- 3683

Sincerely,

       Jill Davis
     Associate Chief Accountant