SEC Comment Letter for FirstCash Holdings, Inc. (FCFS) (CIK 0000840489) (FCFS) — Jan 24, 2012
FirstCash Holdings, Inc. (FCFS) (CIK 0000840489)
Date: Jan. 24, 2012 · CIK: 0000840489 · Accession: 0000000000-12-003924
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19133
Letter
January 24, 2012 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 Response dated January 18, 2012 File No. 000-19133
Dear Mr. Wessel: We have reviewed your response dated January 18, 2012 and have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response.
After reviewing 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. We note your response to our comment rega rding your disclosure of one reportable segment. You state each of your stores w ould meet the definition of an operating segment, that your resources are allocated primarily based on the revenues of individual stores and that you evaluate th e results of individual stores , however you did not consider the aggregation criteria for determining your one reportabl e operating segment; rather you used the “logical management operating struct ure.” We are not persuaded that your use of the logical management operating struct ure instead of the a ggregation criteria set
Rick L. Wessel First Cash Financial Services, Inc. January 24, 2012 Page 2
forth in ASC 280 is appropriate. Please ex plain to us how your use of the “logical management operating structure” complies with ASC 280.
As previously requested, disclose the factor s used to identify your reportable segment and disclose whether operating segments have been aggregated as required by FASB ASC 280-10-50-21(a). Show us what your disclosure will look like revised.
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
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January 24, 2012
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 Response dated January 18, 2012 File No. 000-19133
Dear Mr. Wessel:
We have reviewed your response dated January 18, 2012 and have the following
additional comment. In our comment, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your
response.
After reviewing 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. We note your response to our comment rega rding your disclosure of one reportable
segment. You state each of your stores w ould meet the definition of an operating
segment, that your resources are allocated primarily based on the revenues of individual
stores and that you evaluate th e results of individual stores , however you did not consider
the aggregation criteria for determining your one reportabl e operating segment; rather
you used the “logical management operating struct ure.” We are not persuaded that your
use of the logical management operating struct ure instead of the a ggregation criteria set
Rick L. Wessel First Cash Financial Services, Inc. January 24, 2012 Page 2
forth in ASC 280 is appropriate. Please ex plain to us how your use of the “logical
management operating structure” complies with ASC 280.
As previously requested, disclose the factor s used to identify your reportable segment and
disclose whether operating segments have been aggregated as required by FASB ASC
280-10-50-21(a). Show us what your disclosure will look like revised.
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