SecProbe.io

March 5 , 2014

Via E -mail
Jeffrey A. Williams
Chief Financial Officer
America’s Car -Mart, Inc.
802 Southeast Plaza Avenue, Suite 200
Bentonville , Arkansas , 72712

Re: America’s Car-Mart, Inc.
 Form 10 -K for the Fiscal Year Ended April 30, 2013
Filed June 21, 2013
File No. 000-14939

Dear Mr. Williams :

We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do no t believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Item 7. Management’s Discussion & Analysis, page 20

1. In future filings, please ensure that you provide a balanced, executive level discussion
through the eyes of management that identifies the most important m atters upon which
management focus es in evaluating financial condition and results of operations and
provides a context for the discussion and analysis of your financial statements. It should
also serve to inform readers about how you earn revenue and income  and generate cash
and provide insight into material opportunities, challenges and risks as well as actions
you are taking to address those material opportunities, challenges and risks. Therefore, in
future filings please give consideration to providing:

 An identification and discussion of key variables and other quantitative and
qualitative factors necessary for an understanding and evaluation of  your business and
a discussion  of management’s view of the implications and significance of the
information; a nd

Jeffrey A. Williams
America’s Car-Mart, Inc.
March 5,  2014
Page 2
  A discussion and analysis of material uncertainties and known trends that would
cause reported financial information not to be necessarily indicative of future
operating performance or financial condition to promote an understanding of the
quality and p otential variability of your earnings and cash flows.

In this regard, we believe a more robust discussion of the supply of used cars and trends
therein would be helpful to readers. We note that that the  Form 10 -Q for the  period s
ended October 31, 2013 and January  31, 201 4 discuss  that an increase in the cost of sales
was caused,  in part, “by the overall decrease in new car sales during the recession when
compared to  pre-recession levels.” Please elaborate upon these trends and tell us what
your future  disclosure will look like. In this regard, we also  note your disclosure on page
27 of your annual report that “[t]he purchase price the Company pays for a vehicle has a
significant effect on l iquidity and capital resources…[d] ecreases in the overall volume of
new car sales, particularly domestic brands, lead s to decreased supply in the used car
market.” We also note your indication on page 27 of your annual report that you have
“devoted significant efforts to improve your purch asing processes to ensure adequate
supply at appropriate prices,” however; it’s not clear where you discuss these efforts.
Please tell us what this disclosure will look like.

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 company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and a dequacy of the 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 respect to the filing; and

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

You may contact Jennifer López, Staff Attorney, at (202) 551 -3792 or me at (202) 551 -
3720 with any questions .

Sincerely,

 /s/ Mara L. Ransom

Mara L. Ransom
Assistant Director