SEC Comment Letter for FirstCash Holdings, Inc. (FCFS) (CIK 0000840489) (FCFS) — Feb 21, 2012
FirstCash Holdings, Inc. (FCFS) (CIK 0000840489)
Date: Feb. 21, 2012 · CIK: 0000840489 · Accession: 0000000000-12-009086
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19133
Letter
February 21, 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 February 7, 2012 File No. 000-19133
Dear Mr. Wessel: We have reviewed your response and have th e 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 prior comment one. With regards to the economic characteristics of your operating segments a ddressed in your response, you provided the weighted average store-level operating profit. In accordance with the aggregation criteria in ASC 280-10-50-11, economic characteristics ar e measured at the operating segment level. Please tell us what quantitative meas ures are used to compare your three operating segments with respect to economic similaritie s and provide us that information for each of the last three years and cu rrent interim period. You also provided us with an operating margin range of 19% to 36% for any given ye ar for any segment. Please explain in
Rick L. Wessel First Cash Financial Services, Inc. February 21, 2012 Page 2
greater detail how you considered operati ng margins of 19% and 36% for your operating segments to be similar. Furthermore, provi ding a range for any given year for any given segment makes it difficult to es tablish a correlation. Disc uss and provide support for the economic characteristics you believe are sim ilar and whether you expect similar future prospects.
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 21, 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 February 7, 2012 File No. 000-19133
Dear Mr. Wessel:
We have reviewed your response and have th e 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 prior comment one. With regards to the economic
characteristics of your operating segments a ddressed in your response, you provided the
weighted average store-level operating profit. In accordance with the aggregation criteria
in ASC 280-10-50-11, economic characteristics ar e measured at the operating segment
level. Please tell us what quantitative meas ures are used to compare your three operating
segments with respect to economic similaritie s and provide us that information for each
of the last three years and cu rrent interim period. You also provided us with an operating
margin range of 19% to 36% for any given ye ar for any segment. Please explain in
Rick L. Wessel First Cash Financial Services, Inc. February 21, 2012 Page 2
greater detail how you considered operati ng margins of 19% and 36% for your operating
segments to be similar. Furthermore, provi ding a range for any given year for any given
segment makes it difficult to es tablish a correlation. Disc uss and provide support for the
economic characteristics you believe are sim ilar and whether you expect similar future
prospects.
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