SecProbe.io

April 3, 2013

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, 2012
Filed February 22, 2013
File No. 000-19133

Dear Mr. Wessel :

We have reviewed your filing an d have the following comments.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents.  In some of our comments, we may ask you to
provide us with information so we may better unders tand your disclosure.

Please respond to this letter within ten business days by amending your filing, 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 circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Y ear Ended December 31, 2012

Item 1. Business

Locations and Operations, page 7

1. We note your disclosure that you are an equal partner in Cash & Go, Ltd., a joint venture.
However, you state within Exhibit 21.1 that y ou have a 49.5% ownership interest in Cash
& Go, Ltd.  We also note that you have a 50.0% interest in Cash & Go Management,
LLC.  Please explain in detail the ownership and operating structure of Cash & Go, Ltd.
and Cash & Go Management, LLC as well as how  you account for these investments
citing relevant U.S. GAAP.  Please also specifically address in your response how you
have an equal interest in the Cash & Go, Ltd. joint venture when you have a 49.5%
ownership interest.

Rick L. Wessel
First Cash Financial Services, Inc.
April 3, 2013
Page 2

Item 7. Management’s Discussi on and Analysis of Financial Condition and Results of
Operations

Non-GAAP Financial Information, page 38

2. Please address the following in reference to your  EBITDA Non -GAAP disclosure on
page  39;

 Exchange Act Release No. 47226  describes EBITDA as "earnings before interest,
taxes, depreciation and amortization."   We believe that “earnings” means net
income as presented in the statement of operations under GAAP.   The measure
you reconcile to under the EBITDA header is “[e]arnings from continuing
operations before interest, taxes, depreciation and amortization,” and as such, you
have defined earnings as “earnings from continuing operations” rather than “net
income.”  Measures that are calculated differently than EBITDA as described in
Exchange Act Rele ase No. 47226 should not be characterized as "EBITDA" and
their titles should be distinguished from "EBIT DA," such as "Adjusted EBITDA."
Please revise or tell us why you think your presentation is appropriate.  Refer to
Question 103.0 1 of our Compliance a nd Disclosure Interpretations on Non -GAAP
financial measures  on our website ; and

 We also note your use of income from continuing operations as the most directly
comparable GAAP financial measure in your reconciliation to earnings from
continuing operation s before interest, taxes, depreciation and amortization.  We
believe that if EBITDA is presented as a performance measure, it should be
reconciled to net income as presented in the statement of operations under GAAP.
Please explain or revise.  Refer to Qu estion 103.02 of our Compliance and
Disclosure Interpretations on Non -GAAP financial measures  on our website.

Item 8. Financial Statements and Supplementary Data

Consolidated Statements of Cash Flows, page F -8

3. We note your presentation of pawn loan receivables and consumer loans within investing
activities.  Please tell us whether these amounts are presented net, and if so, revise the
line item heading to state as such.

4. We note your disclosure on page F -10 of the typical terms of pawn and consumer loans.
If pawn loan receivables and consumer loans are presented net within investing activities,
please explain in detail how each of these line items meets the criteria for net presentation
within the consolidated statements of cash flows.  See FASB ASC  230-10-45-7 through
230-10-45-9.  Please specifically address the original maturities of these loans in your
response.

Rick L. Wessel
First Cash Financial Services, Inc.
April 3, 2013
Page 3

5. We note the presentation of borrowings under your revolving unsecured credit facility
within  your consolidated balance sheet as non -current , and the presentation of these
borrowings as net within the financing activities section of your consolidated statements
of cash flows .  Please explain in detail how these borrowings meet the criteria for net
presentation within the consolidated st atements of cash flows.  See FASB ASC 230 -10-
45-7 through 230 -10-45-9.  Please specifically address the original maturities of these
borrowings in your response.

Note 4.  Acquisitions, page F -15

6. We note your disclosure of several acquisitions you consu mmated during the most recent
fiscal year, as well as your table illustrating your allocation of the purchase price.  Please
tell us the nature and amount of the intangible assets recognized.  Additionally, please tell
us what consideration was given to in cluding the disclosures required by ASC 350 -30-50.

7. Please tell us how the acquisitions you made during 2012 were treated for tax purposes.
Please also tell us if the tax allocation of any acquisition resulted in new or changed
intangible asset tax basis  and created deductible amortization of intangibles or goodwill
for tax purposes.  If so, please contrast the allocation performed for tax purposes with that
performed for financial reporting purposes for each acquisition.

Note 9.  Revolving Credit Facili ty and Notes Payable, page F -18

8. We note your disclosure of interest being charged on your borrowings under the
revolving credit facility at the prevailing LIBOR rate plus a fixed spread of 2.0%.  Please
clarify whether LIBOR as used in this note represent s 1 month, 3 month or  some other
LIBOR term and revise other instances where you make this disclosure.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 t he disclosures they have made.

 In responding to our comments, please provide  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

Rick L. Wessel
First Cash Financial Services, Inc.
April 3, 2013
Page 4

  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.

You may contact Jarrett Torno, Staff Accountant , at (202) 551 -3703  or Jason Niethamer,
Assistant Chief Accountant, at (202) 551 -3855 if you have questions regarding comments on the
financial statements and re lated matters.  Please contact me at (202) 551 -3720  with any other
questions.

Sincerely,

 /s/ Andrew D. Mew

Andrew D. Mew
Accounting Branch Chief