SecProbe.io

February 9, 2015

Via E-mail
Mr. Timothy J. Wiggins
Chief Financial  Officer
DeVry Education Group Inc.
3005 Highland Parkway
Downers Grove, IL  60515

Re: DeVry Education Group Inc.
Form 10-K for the Year Ended June 30, 2014
Filed August 27, 2014
Form 10 -Q for the Six Months Ended December  31, 2014
Filed February 5, 2015
File No. 1-13988

Dear Mr. Wiggins :

We have reviewed your filing s and have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents.  Please comply with the following comments in
future filings.  Confirm in writing that you will  do so and explain to us how you intend to
comply.   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 within ten business days by providing the requested
infor mation  or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comme nts, we may
have  additional comments .

Form 10 -K for the year ended June 30, 2014

Financial Aid and Financing Student Education, page 27

1. Refer to the table summarizing the funding source as a percentage of revenue.  Please
provide us with a breakdown of the 32% tuition payments related to “Student accounts,
cash payments, private scholarships, employer and military provided tuition assistance
and other” per geographical area.

Mr. Timothy J. Wiggins
DeVry Education Group Inc.
February 9, 2015
Page 2

Information about Particular Government Financial Aid Programs, page 27

Information about Other Financial Aid Programs, page 29

Brazilian Government Financial Aid Programs , page 30

2. We note that  DeVry  Brasil students are eligible for loans under Bra zil’s FIES public loan
program which is financed by the Brazilian government and PROUNI, a Brazilian
governmental program which provides scholarships to a portion of the undergraduate
students under certain conditions.  Please tell us  how the se programs wor k, including but
not limited to:
 criteria for the student to obtain or earn  the government aid;
 whether the institution needs to return any of the funds in the event the student
withdraws from the course;
 whether the student is responsible for any tuition fees after withdrawal from the
course

3. We note that as of June 30 , 2014, approximately 41% of overall DeVry Brasil’s students
financed their tuition u nder the FIES program while around 11% have obtained
scholarships under the PROUNI program .  Please tell u s how the 48% remainder of
DeVry Brasil’s students finance their tuition.

4. For each funding sources tell us how you evaluate collectability of revenue when a
student begins attending class.

Critical Accounting Policies, page 75

Revenue Recognition, pag e 76

5. Refer to the  last sentence in the first paragraph of page 76.  You state  that the provision
for refunds and the provision for uncollectible accounts   are recognized in the same
ratable fashion as revenue to most appropriately match these costs with t he tuition
revenue in that term.    Please explain to us in detail why the provision for uncollectible
accounts is recognized on the same ratable fashion as revenue. In this regard we note that
this disclosure differs from similar disclosures on page 98. Pl ease clarify this
inconsistency.

Consolidated Statement of Cash Flows, page 93

6. Please refer to the line item “Provision for Refunds and Uncollectible Accounts”. It is
unclear to us why refunds are shown as a reconciling item in the statement of cash flows.
Please revise or advise.

Mr. Timothy J. Wiggins
DeVry Education Group Inc.
February 9, 2015
Page 3

 Note 3 – Summary of Significant Accounting Policies, page 97
Revenue Recognition, page 98

7. We note that the majority of your students fund their education through loans and/or
grants received from U.S. federal financial aid programs estab lished by Title IV of the
Higher Education Act and regulations promulgated thereunder (“Title IV”).   We
understand that when a  student, who has received Federal Student Aid, withdraws from
the University prior to completing a course or pa yment period, the University may have a
return to Title IV requirement. You state that if a student leaves school prior to
completing a term, federal, state and/or Canadian provincial regulations and accreditation
criteria permit DeVry Group to retain only  a set percentage of the total tuition received
from such student, which varies with, but generally equals or exceeds, the percentage of
the term completed by such student. Further you state that payment amounts received by
DeVry Group in excess of such se t percentages of tuition are refunded to the student or
the appropriate funding source.

To help us b etter understand your accounting policy; please provide  us with  the following
information:
 tell us how  you determine  that a  student h as with drawn;
 tell us if you re assess collectability of tuition and fees when a student withdr aws
from a  course, the institution, or otherwise loses Title  IV eligibility;
 tell us about your historical colle ctions experience with students who
become r espons ible for tuition and related fees due  to wi thdrawal or lo ss of
financial aid eligibility; and
 tell us under what circumstances the accreditation criteria allows you to
retain amounts in excess of  the set percentages of tuition.

8. Please disclose your refund policy. Also explain to us what do you mean by “All refunds
are netted against revenue during the applicable academic term.”

9. Refer to the earnings release on October 23, 2014.  We note that your revenue per student
undergraduate a t DeVry University benefitted from underutilization of some planned
scholarships.  Please expand the discussion of revenues in MD&A to describe your
scholarship programs in greater detail, including the financial statement impact of the
programs on the periods presented and any material trends in scholarship programs.

10. Refer to your disclosure of reclassifications on page 103.  We note that you combined
Deferred tuition revenue and Advance tuition payments in one balance sheet line item.
Please revise to separately present these line items if they exceed 5% of total current
liabilities pursuant to Rule 5 -02 of Regulation S -X or tell us why you believe it is
appropriate to combine these items.

Mr. Timothy J. Wiggins
DeVry Education Group Inc.
February 9, 2015
Page 4

 Note 9 – Intangible Assets, page 112

11. Refer to your discussion of tuition rates on page 115.  We note that tuition rates at DeVry
University remain unchanged and that management implemented the DeVry Fixed
Tuition Promise.  We also note that you have added another scholarship program.  Please
expand MD&A to include a discussion of revenues and scholarships that addresses the
impact of scholarships on your tuition revenue. Please revise to separately present these
line items if they exceed 5% of total current liabilities pursuant to Rule 5 -02 of
Regulation S -X.  Please also expand the disclosure on page 115 to incorporate your
scholarship programs into the discussion of the Fixed Tuition Promise, as it may impact
tuition per student if scholarships are significant.

Schedule II -Valuation and Qualifying Accounts and Reserves, page 128

12. Please explain to us what the line item  “Deducted from accounts receivable for refunds”
represents.

Form 10 -Q for Fiscal Quarter Ended December 31 , 2014

13. Refer to the discussion of revenue on page 37.  Please also  expand MD&A to explain in
greater detail what is meant by “the strategic use of scholarships” and include the impact
of scholarships on revenues.

14. Refer to the discussion of Student Payments on page s 40 and 41 .  We note that you
continue to provide finan cing options including your institutional loan programs.  Please
expand the discussion of funding sources to separately disclose the percentage of revenue
from student accounts, to the extent that such accounts are part of the institutional loan
program.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respec t to the filing; and

Mr. Timothy J. Wiggins
DeVry Education Group Inc.
February 9, 2015
Page 5

  the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Claire DeLabar , Senior Staff Accountant, at (2 02) 551 -3349 or Ivette
Leon, Assistant Chief Accountant , at (202) 551 -3351 if you have questions regarding comments
on the financial statements and related matters.  Please contact me at (202) 551 -3810 with any
other questions.

Sincerely,

/s/ Terry French for

Larry Spirgel
Assistant Director