SEC Comment Letter for UPBOUND GROUP, INC. (UPBD) (CIK 0000933036) (UPBD) — May 6, 2014
UPBOUND GROUP, INC. (UPBD) (CIK 0000933036)
Date: May 6, 2014 · CIK: 0000933036 · Accession: 0000000000-14-022974
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May 6, 2014 Via E-mail Mr. Michael S. Wilding Interim Chief Financial Officer Rent -A-Center, Inc. 5501 Headquarters Drive Plano, TX 75024 Re: Rent -A-Center, Inc. Form 10 -K for the Fiscal Year Ended December 31, 20 13 Filed March 3, 2014 File No. 0 -25370 Dear Mr. Wilding : We have reviewed your filing and have the following 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 ten 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 appl ies to your facts and circumstances , please te ll us why in your response. After reviewing the information you provide in response to th is comment, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 20 13 Item 7. Management’s Discussion and Analysis of F inancial Condition an d Results of Operations, page 20 Comparison of the Years Ended December 31, 201 3 and 201 2 1. In future annual and quarterly filings, please provide a discussion of the comparison of the consolidated results between periods that you prev iously provided, as found on pages 28-29 of your Form 10 -K, in addition to your discussion of segment performance. We believe that your previously disclosed narrative provides investors with detailed and quantified information regarding the reasons for si gnificant changes in the line items on your statements of earnings. Mr. Michael S. Wilding Rent -A-Center, Inc. May 6, 2014 Page 2 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 o f 1934 and all applica ble 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 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 Uni ted States. You may contact Dale Welcome at (202) 551 -3865 or me at (202) 551 -3768 if you have questions regarding th is comment. Sincerely, /s/ John Cash John Cash Accounting Branch Chief