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William S. McCalmont

Executive Vice President and Chief Financial Officer

1231 Greenway Drive, Suite 600

Irving, TX 75038

(972) 550-5000

March 18, 2005

Via EDGAR and Overnight Delivery

Mr. Paul Cline, Senior Accountant

Mr. Michael Volley

United States Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

    Re:
    Ace Cash Express, Inc.

Form 10-K for the fiscal year ended June 30, 2004

File Number: 000-20774

Dear Messrs. Cline and Volley:

     Enclosed please find the responses of Ace Cash Express, Inc. (the “Company”) to the comments
received by facsimile on February 16, 2005 from the staff of the Securities and Exchange Commission
(the “Staff”). For ease of review, the Company has set forth below each of the numbered comments
of your letter and its responses thereto. In addition, the Company has, where appropriate,
included proposed revisions to the Company’s disclosure which the Company will include in future
periodic reports filed with the Securities and Exchange Commission. For ease of review, these
proposed disclosure changes have been set forth below as bolded underlined additions to the boxed
disclosure that was included in the Company’s Annual Report Form 10-K for the fiscal year ended
June 30, 2004.

Item 1. Business – page 3

    1.
    Please disclose the year in which you were organized and your form of organization.
Refer to Item 101(A)(1) of Regulation S-K.

Response: In response to the Staff’s comment, in future filings the Company will provide
the following additional disclosure in the overview section of its business description:

We began operations in 1968, and were incorporated as a Texas corporation in March
1982.

    2.
    Please include a reference to your segment disclosures presented in your financial
statements. Refer to Item 101(B) of Regulation S-K.

Response: In response to the Staff’s comment, in future filings the Company will provide
the following additional disclosure in the overview section of its business description:

Our reportable segments are strategic business units that differentiate between
company-owned and franchised stores. Company-owned store revenue is generated from
customer-transaction processing in stores owned by the Company, and franchised store
revenue is generated from the franchise fees charged for opening the franchised store and
on-going royalty fees received from franchisees. For more information on our segment
financial information, please see Note 2 to the Company’s Consolidated Financial
Statements.

    3.
    Please disclose your Internet address. Refer to Item 101(E)(3) of Regulation S-K.

Response: In response to the Staff’s comment, in future filings the Company will provide
the following additional disclosure in the overview section of its business description:

Website Access to Reports. Through our website at www.acecashexpress.com, we provide
free access to our Annual Report on Form 10-K, Quarterly Reports on Form 10-Q, Current
Reports on Form 8-K, Forms 3, 4 and 5 filed by reporting persons, and all amendments
thereto, as soon as reasonably practicable after such reports are electronically filed with
the Securities and Exchange Commission.

    4.
    Please disclose whether you make available free of charge on or through your Internet
website your filed financial reports as soon as reasonably practicable after you
electronically file such material with the SEC. Refer to Item 101(F)(4) of Regulation
S-K.

Response: Please see the Company’s response to Comment # 3.

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Growth Strategy – page 5

    5.
    Please expand your discussion and/or add a discussion related to your strategies and
key decision making factors related to the following activities:

    a. Acquiring new owned stores;

    b. Opening new owned stores;

    c. Selling existing owned stores;

    d. Closing existing owned stores;

    e. Opening new franchised stores;

    f. Acquiring new franchised stores;

    g. Closing existing franchised stores.

In your summary of significant accounting policies, please discuss your accounting policies
relating to each of the above activities specifically disclosing how you account for the
purchase or sale price and how you calculate and record gains or losses.

Response: In response to the Staff’s comment, in future filings the Company will provide
additional disclosures substantially similar to the following in the referenced section of
its business description:

Growth Strategy

A key objective of our network growth strategy is to have the most locations in
each market and to offer the broadest selection of financial services in our
industry. We believe that by offering the convenience of high-density store
locations, exceptional customer service and a broad suite of retail financial
services, we will achieve a high level of customer satisfaction. The key
elements of our growth strategy are as follows:

Open Company-Owned Stores.

We have identified several key geographic areas or markets for the development
of both ACE Cash Express stores as well as ACE Cash Advance stores. These
markets were identified following a review of the top 270 Standard Metropolitan
Statistical Areas in the United States and an internal evaluation of each
market’s ability to support our store development program.

Specific trade areas are identified within each geographic market based upon
our assessment of the area’s demographics and traffic patterns. Our real
estate department then seeks to identify specific site locations within each
trade area. The specific site is then presented for approval to our Capital
Approval Committee consisting of our President & CEO, our EVP of Operations and
our EVP & Chief Financial Officer.

The Capital Approval Committee bases its decision to approve a specific site
and to pursue the development of a store on such factors as the terms of the
lease, the visibility of the store, the capital cost of the proposed store and
the trade area’s demographics.

We opened 53 company-owned stores in fiscal 2004 (including 11 ACE Cash
Advance stores), compared to 14 stores in fiscal 2003 and 39 stores in fiscal
2002. Our company-

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owned store growth in fiscal 2003 was less than our
historical new store growth primarily due to limitations on capital
expenditures imposed by our bank credit agreement through March 31, 2003. Our
current bank credit agreement enables us to pursue our company-owned store
growth strategy more aggressively. We expect to open approximately 60 new
company-owned stores, with a net gain of approximately 40 to 45 company-owned
stores after store closures, in fiscal 2005. We are still targeting an
aggregate net gain of approximately 300 company-owned stores for the five-year
period ending June 30, 2008.

A decision to close a store is typically based upon store performance or our
inability to obtain favorable lease renewal terms. Company-owned stores are
evaluated for closure during our quarterly business reviews and at the end of
the store’s lease term or any renewals of the lease term. A landlord may also
choose not to renew the lease at the end of its term. We closed 24 stores in
fiscal 2004 compared to 28 stores in fiscal 2003 and 32 stores in fiscal 2002.
This represents 2%, 3%, and 3% of total company-owned stores as of June 30,
2004, 2003 and 2002, respectively.

Company-owned stores are sold infrequently. Company-owned stores that are sold
are typically located in isolated geographic areas that do not fit into our
overall strategic geographic development plans. We sold 5 stores in fiscal
2004, compared to 23 stores in fiscal 2003, and sold no stores in fiscal 2002.

Accelerate Franchise Store Development.

Our goal is to be the industry leader in offering quality franchising
opportunities and exceptional support systems and services to existing and
potential franchisees. We believe that by offering attractive investment
opportunities and exceptional franchisee support systems and services, we will
attract potential franchisees to partner with us rather than other franchisors.

Our franchise department seeks to locate franchised stores in geographic
markets that are not designated for company-owned development. The franchise
department targets specific trade areas within each geographic market and
identifies potential franchisees within these trade areas. These potential
franchisees are then contacted to determine their level of interest in
developing an ACE Cash Express store. Potential franchisees interested in
developing stores also contact the franchise department directly.

We opened 32 franchised stores in fiscal 2004, compared to 26 stores in fiscal
2003 and 22 stores in fiscal 2002. As of June 30, 2004, we had 204 franchised
stores and we believe our targeted markets could potentially support an
additional 1,800 ACE franchise stores across the United States. We expect to
open approximately 50 new franchised stores, with a net gain of approximately
40 franchised stores after store closures, in fiscal 2005. Currently, we have
franchise agreements for the development of over 100 new franchise stores and
we are still targeting an aggregate net gain of approximately 200 franchise
stores for the five year period ending June 30, 2008.

A franchise agreement may be terminated if the franchisee does not comply with
the franchise agreement. Subject to the terms of the franchise agreement, a
franchisee may also elect to voluntarily close a store or leave the ACE system
based upon a variety of factors specific to the individual franchisee. In
either case, we consider

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these closed stores, whether or not the store actually
closes or is re-branded. In fiscal 2004, 15 franchised stores were closed,
compared to 8 franchised stores in fiscal 2003 and 5 franchised stores in
fiscal 2002.

Pursue Opportunistic Acquisitions.

A key element of our network growth strategy is to acquire existing
check-cashing stores and to re-brand them as ACE Cash Express stores. Since
1991, we have acquired over 500 check-cashing stores. We have not acquired any
monoline payday loan stores but may do so in the future.

Our evaluation of an acquisition candidate is based upon that store’s existing
revenue and cash flow, our ability to introduce additional services enhancing
revenue growth, our assessment of the stores geographic market and its
consistency with our strategic development plans and our expectation that we
can introduce our proprietary information systems and Operational Goals to the
store generating operating efficiencies.

A decision to acquire a store is reached following an assessment of the factors
noted above and a financial review of our anticipated return on investment.
Acquisitions requiring an investment of greater than $1 million are approved by
our Board of Directors.

We believe that our extensive experience with acquisitions allows us to
efficiently integrate acquired stores into our network. In fiscal 2004, we
acquired 34 stores compared to 2 stores in fiscal 2003 and 8 stores in fiscal
2002.

The Company advises the Staff that in future filings it will provide additional disclosures
substantially similar to the following in Note 1 to the Company’s Consolidated Financial
Statements:

1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

New Store Accounting

Start-up costs for new stores such as training, supplies and travel are expensed as
incurred.

Store Acquisition Accounting

We account for all store acquisitions using the purchase method of accounting. This
method requires the allocation of the purchase price to individual tangible assets
acquired, intangible assets acquired arising from contractual or legal rights, and
liabilities assumed based on their estimated fair values at the date of acquisition. The
excess of the cost of acquired assets over the net amounts assigned to assets acquired and
liabilities assumed is recognized as goodwill. Any costs, including “out-of-pocket” or
incremental costs directly related to the acquisition, such as fees

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paid to outside consultants for accounting, legal, or engineering investigations or for
appraisals, are included in the cost of the acquired assets.

Gain or Loss on Store Closure

We close stores in the normal course of business based on store performance, lease
termination or unfavorable lease extension terms. For closed stores, we record a loss in
other expense for the write-off of any remaining book value of fixed assets not transferred
to other locations and any related closing costs. For stores sold to third parties, a gain
or loss is recorded based on the amount received less the write-off of any remaining book
value of fixed assets not sold or transferred to other locations and any related closing
costs.

Introduce New Services – Page 6

    6.
    Please revise to provide an expanded discussion of the nature of your relationship
with NetSpend, including whether you have a written agreement and, if so, its material
terms.

Response: In future filings the Company will provide additional disclosures substantially
similar to the following regarding the NetSpend relationship in the referenced section of
its business description:

Introduce New Services. In addition to our current broad service offering, we
continuously evaluate new services for possible introduction into our stores. For example,
in fiscal 2002, we entered into a written agreement with NetSpend Corporation, a
prepaid payments company, whereby we offer prepaid debit cards in our stores. The
MasterCard® prepaid debit card offered through NetSpend allows our customers to
“load” cash onto these cards and use them wherever MasterCard debit cards are
accepted.  Pursuant to our agreement, we receive from the customer a portion of
the purchase price of the cards and a convenience fee for loads on the cards. In
addition, we receive from NetSpend an additional portion of the purchase price of the card
and commissions based on the aggregate amount loaded or direct deposited on the cards, the
number of purchases or ATM withdrawal transactions made with the cards and account
maintenance and subscription fees paid by the customer. Our agreement with NetSpend
expires on March 31, 2007, and will automatically renew for one year periods thereafter
absent 365 days’ prior notice by either of the parties. Either party may terminate the
agreement at an earlier date if the non-terminating party (i) fails to pay to the
terminating party amounts when due, (ii) fails to timely cure a default under the agreement
or (iii) is bankrupt or insolvent. During fiscal 2004, we and our franchisees sold
approximately 149,000 cards and loaded a total face value of more than $268 million.
Revenues generated under this NetSpend agreement during fiscal 2004, 2003, and 2002
were $4.6 million, $2.7 million, and $0.5 million, respectively, which represents 1.9%,
1.2% and 0.0% of our net revenues for such periods, and are included in Bill Pay
revenue. We believe that our distribution network, with 1,230 network stores in 36
states and the District of Columbia, makes us an ideal partner for financial service
companies seeking to gain immediate access to our customer base. Our distribution network
allows us to offer our customers new services through third parties, without incurring the
costs associated with a proprietary research and development process.

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Check Cashing – page 7

    7.
    Please revise here and in the footnotes to the financial statements to disclose and
discuss your policy for recognizing fee revenue on cashed checks. Clarify whether or not
you record them net of an allowance for anticipated returned checks or how you otherwise
account for fee revenues on returned checks. Quantify in MD&A the amount of fee revenue
associated with returned checks.

Response: In response to the Staff’s comment, the Company advises the Staff that in future
filings it will provide additional disclosu