SecProbe.io

December 12, 2011
 Via E-mail

Rick L. Wessel Chief Executive Officer First Cash Financial Services, Inc. 690 East Lamar Blvd., Suite 400 Arlington, TX 76011
Re: First Cash Financial Services, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 25, 2011 File No. 000-19133

Dear Mr. Wessel:
 We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with informati on 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 comment applies 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 this comment, we may have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2010

           Notes to Consolidated Financial Statements

 Note 16 – Geographic Areas

1. You disclose here that you manage your busin ess on the basis of one reportable segment.
We also note that you have identified thr ee reporting units, or components, for the
purpose of measuring the recoverability of  goodwill: U.S. Pawn Operations, U.S. Short-
Term Loan Operations, and Mexico Operati ons as disclosed in Note 13 as well as
disclosure included elsewhere, such as Ma nagement’s Discussion and Analysis, based on
the geographic locations and the nature of your operations.  Please explain to us the
extent you considered whether these three comp onents represent reportable segments.

Rick L. Wessel First Cash Financial Services, Inc. December 12, 2011 Page 2

 Please provide us with your analysis under ASC 280 that supported disclosing all
operations as one reportable segment.  Pleas e include the following information in your
response:
 the operating segments you have identif ied in accordance with ASC 280-10-50-1
through 50-9,
 the factors used to identify reportable segments,
 your basis for aggregating identified opera ting segments into a single reportable
segment given the aggregation criter ia in ASC 280-10-50-11 and quantitative
thresholds in ASC 280-10-50-12.
 how the aggregation of all of your op erations into one reportable segment
complies with the aggregation criteria, and
 the process through which your chie f operating decision maker reviews
information to make decisions about res ources to be allocated to your segment
and assess its performance.

In addition, please disclose the factors you us ed to identify your reportable segment and
whether operating segments have been a ggregated as required by ASC 280-10-50-21.

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  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 person under the federal securities laws of the United
States.

Rick L. Wessel First Cash Financial Services, Inc. December 12, 2011 Page 3

 You may contact Scott Stringer , Staff Accountant, at (202) 551-3272 or Donna Di Silvio,
Staff Accountant, at (202) 551-3202 if you have questions regarding comments on the financial
statements and related matters.  You may contact  me at (202) 551-3720 with any other questions.

Sincerely,
    /s/ Andrew D. Mew
 Andrew D. Mew Accounting Branch Chief