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SEC Comment Letter for REGIS CORP (RGS) (CIK 0000716643) (RGS) — Mar 2, 2018

REGIS CORP (RGS) (CIK 0000716643)
Date: March 2, 2018 · CIK: 0000716643 · Accession: 0000000000-18-006667

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File numbers found in text: 001-12725

Date
March 1, 2018
Author
Andrew Lacko
Form
UPLOAD
Company
REGIS CORP (RGS) (CIK 0000716643)

Letter

March 1, 2018 Andrew Lacko Executive Vice President and Chief Financial Officer Regis Corporation 7201 Metro Boulevard Edina, MN 55439 Re:Regis Corporation Form 10-K for Fiscal Year Ended June 30, 2017 Filed August 23, 2017 10-Q for the Quarterly Period Ended December 31, 2017 Filed February 1, 2018 File No. 001-12725 Dear Mr. Lacko: We have reviewed your filings and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the Quarterly Period Ended December 31, 2017 Note 5. Income Taxes, page 11 1.We note your disclosure in the last paragraph on page 11 that the tax law change allows for the indefinite carryforward of NOLs arising in tax years ending after December 31, 2017. Please explain to us how this tax law change enabled you to partially release your valuation allowance on deferred tax assets, as it appears that the deferred tax assets arose prior to December 31, 2017. Also, tell us the amount of the tax benefit for the partial release the valuation allowance. In addition, explain to us the reason why you recorded $7.6 million of tax benefit, exclusive of the $68.9 million benefit, due to the Tax Act and the resulting partial release of the Company's valuation allowance..

FirstName LastNameAndrew Lacko Comapany NameRegis Corporation June 16, 2017 Page 2 FirstName LastName Andrew Lacko Regis Corporation March 1, 2018 Page 2 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 Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Carlos Pacho, Senior Assistant Chief Accountant at (202) 551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer, Staff Attorney at (202) 551-3415 or Celeste Murphy, Legal Branch Chief at (202) 551-3257 with any other questions.

Division of Corporation Finance AD 11 -Office of Telecommunications

Show Raw Text
March 1, 2018
Andrew Lacko
Executive Vice President and Chief Financial Officer
Regis Corporation
7201 Metro Boulevard
Edina, MN 55439
Re:Regis Corporation
Form 10-K for Fiscal Year Ended June 30, 2017
Filed August 23, 2017
10-Q for the Quarterly Period Ended December 31, 2017
Filed February 1, 2018
File No. 001-12725
Dear Mr. Lacko:
            We have reviewed your filings and have the following comment.  In our comment, we
ask you to provide us with information so we may better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended December 31, 2017
Note 5. Income Taxes, page 11
1.We note your disclosure in the last paragraph on page 11 that the tax law change allows
for the indefinite carryforward of NOLs arising in tax years ending after December 31,
2017.  Please explain to us how this tax law change enabled you to partially release your
valuation allowance on deferred tax assets, as it appears that the deferred tax assets arose
prior to December 31, 2017.  Also, tell us the amount of the tax benefit for the partial
release the valuation allowance.  In addition, explain to us the reason why you recorded
$7.6 million of tax benefit, exclusive of the $68.9 million benefit, due to the Tax Act and
the resulting partial release of the Company's valuation allowance..

 FirstName LastNameAndrew Lacko
 Comapany NameRegis Corporation
 June 16, 2017 Page 2
 FirstName LastName
Andrew Lacko
Regis Corporation
March 1, 2018
Page 2
            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  Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or
Carlos Pacho, Senior Assistant Chief Accountant at (202) 551-3835 if you have questions
regarding comments on the financial statements and related matters.  Please contact Paul
Fischer, Staff Attorney at (202) 551-3415 or  Celeste Murphy, Legal Branch Chief  at (202)
551-3257 with any other questions.

Division of Corporation Finance
AD 11 -Office of
Telecommunications