SecProbe.io

December 22, 2010
  Rick L. Wessel Chief Executive 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 Fiscal Year Ended December 31, 2009
Filed March 15, 2010 File No. 000-19133

Dear Mr. Wessel:
 We have reviewed your filing and 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 advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
          Form 10-K for Fiscal Year Ended December 31, 2009

 Item 8. Financial Statements and Supplementary Data

 Notes to Consolidated Financial Statements

 Note 13 – Goodwill and Other Intangible Assets

 1. We note your footnote disclosures regardi ng the company’s goodwill balance for each
period reported.  Please tell us your consider ation for providing a discussion of your
goodwill valuation process within the cri tical accounting policies section of
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
given the material nature of your goodwill bala nce.  Please note that these disclosures
should provide investors with sufficient information as well as management’s insights
and assumptions with regard to the recoverabi lity of goodwill.  In this regard, we have

Mr. Rick L. Wessel  First Cash Financial Services, Inc.  December 21, 2010  Page 2

identified areas where we believe additional discussion would enhance your disclosures.
Specifically, we believe you s hould provide the following info rmation pursuant to Item
303(a)(3)(ii) of Regulation S-K and Financia l Reporting Release No. 60 and Section V of
SEC Release No. 33-8350:
• Please tell us the reporting units, as de fined in ASC 350-20, used in your analysis;
indicate how the reporting units are inde ntified; provide th e amount of goodwill
allocated to each reporting unit and explai n how you estimate the fair value of each
reporting unit;
• Please provide the carrying value and fair valu e for each reporting unit as of the date
of your most recent step-one test.  Alternat ively, disclose the percentage by which the
fair values exceed the carrying values for each unit;
• For those reporting units in which the fair values do not exceed their carrying values
by significant amounts, please describe th e potential events and/or changes in
circumstances that could r easonably be expected to ne gatively affect the key
assumptions used in determining fair value.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:

• the company is responsible for the adequacy an d accuracy of the disclo sure 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 person under the federa l securities laws of  the United States.

You may contact Milwood Hobbs, Staff Accountant, at (202) 551-3241, or Jason
Niethamer, Assistant Chief Accountant, at (202) 551-3855 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact me at (202) 551-3720
with any other questions.
Sincerely,

Andrew Mew  Accounting Branch Chief