SEC Comment Letter for FirstCash Holdings, Inc. (FCFS) (CIK 0000840489) (FCFS) — Feb 1, 2012
FirstCash Holdings, Inc. (FCFS) (CIK 0000840489)
Date: Feb. 1, 2012 · CIK: 0000840489 · Accession: 0000000000-12-005588
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19133
Letter
February 1, 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 27, 2012 File No. 000-19133
Dear Mr. Wessel: We have reviewed your response and have th e following additional comments. In our comments, 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 comments apply to your facts and circum stances, please tell us w hy in your response. After reviewing the information you provide in response to these comments, 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 proposed disclosure stating in dividual stores and regional geographic markets have been aggregated into one re portable segment. If, as you state in your response, that each individual store is an operating segment, please tell us what your regional geographic markets represent. Furthe r, if your regional geographic markets are not operating segments, please tell us the guidance you relied upon fo r aggregation with the individual stores, i.e., operating segments.
2. Your accounting policy for goodwill states you identified three reporting units or components for the purpose of measuring th e recoverability of goodwill: U.S. Pawn
Rick L. Wessel First Cash Financial Services, Inc. February 1, 2012 Page 2
Operations, U.S. Short-Term Loan Operati ons and Mexico Opera tions. A reporting unit is an operating segment or one level belo w an operating segment, a component. You have stated that each individual store re presents an operating segment under ASC 280. Please explain how the three reporting units U.S. Pawn Operations, U.S. Short-Term Loan Operations and Mexico Operations identified under ASC 350-20-35 for the purpose of measuring the recoverability of goodwill relate to your operating segments which you identified as individual stores.
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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February 1, 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 27, 2012 File No. 000-19133
Dear Mr. Wessel:
We have reviewed your response and have th e following additional comments. In our
comments, 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 comments apply to your facts and circum stances, please tell us w hy in your response.
After reviewing the information you provide in response to these comments, 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 proposed disclosure stating in dividual stores and regional geographic
markets have been aggregated into one re portable segment. If, as you state in your
response, that each individual store is an operating segment, please tell us what your
regional geographic markets represent. Furthe r, if your regional geographic markets are
not operating segments, please tell us the guidance you relied upon fo r aggregation with
the individual stores, i.e., operating segments.
2. Your accounting policy for goodwill states you identified three reporting units or
components for the purpose of measuring th e recoverability of goodwill: U.S. Pawn
Rick L. Wessel First Cash Financial Services, Inc. February 1, 2012 Page 2
Operations, U.S. Short-Term Loan Operati ons and Mexico Opera tions. A reporting unit
is an operating segment or one level belo w an operating segment, a component. You
have stated that each individual store re presents an operating segment under ASC 280.
Please explain how the three reporting units U.S. Pawn Operations, U.S. Short-Term
Loan Operations and Mexico Operations identified under ASC 350-20-35 for the purpose
of measuring the recoverability of goodwill relate to your operating segments which you
identified as individual stores.
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