SecProbe.io

Mail Stop 3561          August 18, 2009   R. Douglas Orr,
Executive Vice President and Chief Financial Officer
First Cash Financial Services, Inc.  690 East Lamar Blvd., Suite 400 Arlington, Texas 76011
 Re:  First Cash Financial Services, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2008
  Filed March 16, 2009
  Definitive Proxy Statement on Schedule 14A
Filed April 30, 2009
Forms 10-Q for the Fiscal Quarters Ended March 31, 2009 and June 30, 2009
Filed May 8, 2009, August 4, 2009
  File No. 000-19133
Dear Mr. Orr:

We have reviewed your filings and have the following comments.  You should comply
with the comments in all future filings, as appl icable.  Please confirm in writing that you will do
so and also explain to us in sufficient detail for an understa nding of the disclosure how you
intend to comply by providing us with your prop osed revisions.  If you disagree, we will
consider your explanation as to why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry in your explanation.  After re viewing this information, we may
raise additional comments.
  Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filings.  We look forward to working with  you in these respects.  We welcome any
questions you may have about our comments or any other aspect of our review.  Feel free to call
us at the telephone numbers listed  at the end of this letter.

R. Douglas Orr
First Cash Financial Services, Inc.  August 17, 2009  Page 2   Form 10-K for the Fiscal Year Ended December 31, 2008

 Item 1. Business, page 4

 Short-Term Loan and Credit Services Activities, page 7

 1. Given that you state that the profitability of the Company’s short-term operations is dependent upon adequate collection of these re turned items, please  quantify, by way of
percentage or other means, the “significant number” of customer checks that are returned for insufficient funds and the “large percentag e” that you subsequently  collect from your
customers.
 2. With respect to your CSO program, please quanti fy by way of percentage or other means the
“significant number” of custom er checks deposited into the i ndependent lender's account due
to insufficient funds in the customers' accounts and the amount you subsequently collect.
 Item 2. Properties, page 21

 3. We note that the leases on your pawn and shor t-term
  loan operations expire anywhere from
2009 through 2019  Please state the approximate nu mber of leases that are set to terminate
over the next fiscal year and provide your gene ral belief as to the likelihood that you will be
able to renew these leases.  We note your st atement of belief that termination of any
particular lease would not have a material  adverse effect on the Company’s operations;
please advise if you believe that the failure to re new the leases set to expire in the next year
will have a material impact  on your operations.
 Item 7. Management's Discussion and Analysis  of Financial Condition and Results…, page 25

General

4. Please expand your discussion to discuss known material trends, demands, commitments,
events, or uncertainties that will have, or are reasonably likely to have, a material impact on
your financial condition, operating performance,  revenues, or income, or result in your
liquidity decreasing or increasing in any material way.  In  doing so, provide additional
information about the quality and variability of your earnings and cash flows so that investors
can ascertain the likelihood of the extent past performance is indicative of future performance.  In addition, please discuss in reasonable detail:
• economic or industry-wide factors relevant to your company, and
• material opportunities, challeng es and risks in short and l ong term and the actions you are
taking to address them.

For example, we note that you discontinued you r short-term loan operations in Washington

R. Douglas Orr
First Cash Financial Services, Inc.  August 17, 2009  Page 3
D.C. due to legislation that capped the interest  rate that you could charge for these loans.
Please identify, to the extent you know, any othe r jurisdictions in which you operate that
maybe close to passing similar legislation, wh ich if enacted, may result in you ceasing your
short-term loan operations in that jurisdiction.  Please discu ss how the cessation of such
operations would affect your overa ll operations and liquidity.  Also, in light of the current
economic turmoil in the U.S. and Mexico, to the extent material, you should discuss the
affect that the current econo mic turmoil may have on your ability to recoup amounts due on
loans that are in default.  Please see Item  303 of Regulation S-K and SEC Release No. 33-
8350.
Liquidity and Capital Resources, page 38

 5. We note that you intend to continue expansi on primarily through ne w store openings.  We
further note your indication that “the major ity of capital expenditures, working capital
requirements and start-up losses related to this  expansion are expected to be funded through
operating cash flows and the credit facilities.”  Please revise to quantify how much you will
need in order to proceed with your expansion plans this fiscal year and how much you spent
last fiscal year.  Also, as you i ndicate that “the majority” of such costs will come from the 2
sources you mention, please disclose the source(s ) of any remaining costs.  Refer to Item
303(a)(2) of Regulation S-K.
Item 7A. Quantitative and Qualitative Disclosures About Market Risk, page 44

 6. We note that your operations face market risk fr om the potential change in interest rates,
foreign exchange rates, and gold prices.  Pl ease discuss how you mana ge, if at all, your
exposures to these risks.  Please refer to Item 305(b) of Regulation S-K.
 Item 9A. Disclosure Controls and Procedures, page 45

 Evaluation of Disclosure Cont rols and Procedures, page 45

 7. In the final sentence of the third paragraph in th is section it states “fin ancial controls” rather
than “disclosure controls.”  In future filings, please state “disclosure controls” rather than
“financial controls” when sta ting your management’s conclusi on regarding the effectiveness
of your disclosure controls and procedures.  Please confirm your understanding in this
regard.

Management's Report on Internal Contro l Over Financial Reporting, page 45

8. We note that your management “believes th at, as of December 31, 2008, the Company's
internal control over financ ial reporting is effective…”  Please confirm that your
management “concluded” that your internal c ontrols over financial reporting were effective
as of December 31, 2008.  In future fili ngs please provide the conclusion of your
management regarding the eff ectiveness of your internal c ontrols over financial reporting,

R. Douglas Orr
First Cash Financial Services, Inc.  August 17, 2009  Page 4
rather than their belief as to the effectiven ess of your internal controls over financial
reporting.  Please confirm your unde rstanding in this regard.
 Exhibits and Financial Statements Schedules, page 48

 Rule 13a-14(a)/15(d)-14(a) Certifications, Exhibit 31.1 and 31.2

                                                                                                                          9. The certification required by Exchange Act Rule 13a-14(a) that you filed as an exhibit to
your Form
 10-K for the fiscal year ended December 31, 2008 and the fiscal quarter ended
March 31, 2009 varies from the exact language of Item 601(b)(31) of Regulation S-K.  For example, you excluded the language in the parent hetical in paragraph 4.  Your certifications
should appear exactly as set forth in current  Item 601(b)(31) of Regulation S-K.  Please
confirm your understanding in th is regard and revise.
 Signatures, page 50

 10. Your Form 10-K is not signed as provided in the Form.  In this regard, it appears that Mr. Orr
signed on behalf of the registrant, but did not sign as your principal financial and accounting
officer.  In this regard, please confirm that Mr. Orr signed your Form 10-K  in his capacity as
your principal financial and accounti ng officer.  Also, in future filings please insure that your
principal executive, financial and accounting officer sign in their capacities as such.  Please
see Form 10-K and General Instru ction D.(2) to Form 10-K.
 Definitive Proxy Statement on Schedule 14A

 Executive Compensation, page 12

 Compensation Discussion and Analysis, page 12

 Base Salary, page 12

11. We note your indication under “Other Items”  that your Com pensation Committee has not
conducted a formal compensation benchmarking study.  However, you also state that you
have set various elements of your compensa tion at competitive levels.  Revise your
disclosure to explain how you have determin ed that such amounts are competitive if you
haven’t engaged in benchmarking.  For example, you state here that base  salary levels “are
set generally to be competitive in relation to the salary levels of executive officers in other
companies within the specialty consumer finan ce industry or other comp anies of comparable
size…”  See Item 402(b)(2)(xiv) of Regulat ion S-K and Question 118.05 of our Regulation
S-K Compliance and Disclosure Interp retations located at our web-site, www.sec.gov .
12. We note that your Compensation Committee set th e salary of  your executives based, in part,
on your subjective assessment of the executive’s performance dur ing the prior fiscal year.
Please discuss specific elements of individua l performance that the Compensation Committee

R. Douglas Orr
First Cash Financial Services, Inc.  August 17, 2009  Page 5
considered when making their subjective assess ment of each executive’s performance during
the past fiscal year.  Please see Item 402(b)(2)(vii) of Regulation S-K.
 Short-Term Incentive Compensation, page 12

 Annual Cash Bonuses, page 12

 13. We note your disclosure that the amount paid to each ex ecutive officer under your Annual
Cash Bonus program reflects corporate pe rformance and the i ndividual executive’s
performance.  We also note that you target bonus payments to range from 20% to 200% of
the executive’s salary.  To the extent that  the amount of each payment is based upon pre-
defined performance targets, please disclose those targets and discu ss how you calculate the
amount to be paid as well as how you arrive at the range of payments.  To the extent that the
amount of each payment is discretionary, please  discuss in greater de tail the elements of
corporate performance and the individual ex ecutive officer’s performance that the
Compensation Committee considered in setting each 2008 bonus payment.
 Executive Incentive Performance Plan, page 13

 14. Please explain why only your Chief Executive Officer appears to be eligible for compensation under this plan.
 15. We note that your Chief Executive Officer has the potential to receive annual incentive
compensation based upon the achievement of certain performance goals set by the Compensation Committee.  We also note that the Chief Executive Officer did not receive a payment under this plan for the year ended December 31, 2008.  Please expand your
disclosure to discuss in mo re detail your Executive Ince ntive Performance Plan.  In
particular, please discuss the performance goa ls that your Chief Executive officer had to
achieve in 2008 to receive payment under the pl an, including a quantitative discussion of any
specific targets and why the Chief Executive Offi cer did not receive a payment for the year
ended December 31, 2008.  Also, please disclose the targets or, to the extent you believe
disclosure of the targets are not required becau se it would result in co mpetitive harm, provide
us on a supplemental basis a detailed explan ation under Instruction 4 to Item 402(b) of
Regulation S-K for this conclusi on.  If disclosure of the perf ormance-related factor would
cause competitive harm, please discuss how difficu lt it will be for the executive or how likely
it will be for you to achieve the target levels or other factors.  Pl ease also discuss any
discretion that you can exercise in granting an award under this pl an absent of the attainment
of the stated performance goal.  Please see In struction 4 to Item 402( b) of Regulation S-K
and Question 118.04 of our Regul ation S-K Compliance and Di sclosure Interpretations
located at our web-site, www.sec.gov.
 16. Please revise your Grants of Plan-Based Award s table, as appropriate, to disclose the
potential payout that your Chief Executive Officer  could have received if he satisfied the

R. Douglas Orr
First Cash Financial Services, Inc.  August 17, 2009  Page 6
threshold, target or maximum performance goals of the Executive Incentive Performance
Plan or advise why you are not required to do so .  Please see Item 402(d) of Regulation S-K.

Long-Term Incentive Compensation, page 13

 17. We note that, in general, you did not make a ny equity awards to your named executives in
2008 because of the size and structure of the aw ards that you made in 2005.  Please discuss
what about the structure and size of the awards  you made in 2005 led you to conclude not to
issue any additional equity awards to your key executives in 2008.
 Summary Compensation Table, page 14

 18. Please tell us why you determined it was appropr iate for you to list the compensation paid to
Phillip E. Powell under the All Other Compen sation column of your Summary Compensation
table rather than your salary column.

19. Please describe your methodology for computing the aggregate incremental cost of Phillip E.
Powell’s and Rick L. Wessel’s use of the corporat e aircraft.  Please see Instruction 4 to Item
402(c)(2)(ix) of Regulation S-K.

20. We note the change-of-control payments that  are applicable to certain of your named
executive officers.  While the Commission has not mandated tabular disclosure of potential
post-employment payments, we encourage you to pres ent this information in future filings in
a tabular format so that investors may asse ss clearly the amount of  compensation to be
received under the various scenarios that would lead to a named executive officer’s
termination or change in contro l of the company. See section VI  of the Securities Act Release
33-8732A.
 Review, Approval, or Ratification of Tran sactions with Related Persons, page 21

 21. Please revise this section to provide addi tional information rega rding your policies and
procedures relating to the review and approva l of transactions with  related persons, as
required pursuant to Item 404(b) of Regulation S-K.  Specifically, indicate the factors you
consider when assessing whether or not to ap prove a related party transaction and whether
these policies and procedures ar e in writing and if not, how your  policies and procedures are
evidenced.

* * * * *

Please respond to these comments within 10 business days or tell us when you will
provide us with a respo
nse.  If you amend one of  your filings, you may wish to provide us with
marked copies of the amendment to expedite our review.  Please furnish a letter that keys your
responses to our comments and provides any re quested information.  Detailed letters greatly

R. Douglas Orr
First Cash Financial Services, Inc.  August 17, 2009  Page 7  facilitate our review.  Please understand that we may have additional comments after reviewing
your amendment and responses to our comments.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in these filings to be certain that the filings include all information required under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts