SEC Comment Letter for UPBOUND GROUP, INC. (UPBD) (CIK 0000933036) (UPBD) — Apr 21, 2017
UPBOUND GROUP, INC. (UPBD) (CIK 0000933036)
Date: April 21, 2017 · CIK: 0000933036 · Accession: 0000000000-17-013899
AI Filing Summary & Sentiment
Reasoning
Letter
April 21, 2017 Thomas W. Hughes , Esq. Winston & Strawn LLP 2501 N. Harwood Street 17th Floor Dallas, Texas 75201
Re: Rent -A-Center, Inc. Preliminary Proxy Statement on Schedule 14A Filed April 11, 201 7 File No. 1-38047
Dear M r. Hughes :
We have reviewed the filing above and have the following comment . After reviewing any amendment to the filing and the information you provide in response to this comment, we may have additional comments. All defined terms used in this letter have the same meaning as in the preliminary proxy statement unless otherwise indicated.
We note that the prelimi nary proxy statement indicates that the record date for the Annual Meeting was April 10. It is our understanding that the record date has been changed to April 24. Please ensure the disclosure in the proxy statement is revised to reflect this new date. Please also tell us how the Company has complied with Exchange Act Rule 14a -13(a)(3) with respect to this solicitation. Include in your response the date that the Company conducted the inquiry required by Rule 14a -13(a)(1). It is our understanding that that the Company may have conducted such inquiry on April 20 notwithstanding a record date of April 24.
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We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact me at (202) 551 -3444 with any questions.
Sincerely ,
/s/ Perry J. Hindin
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April 21, 2017 Thomas W. Hughes , Esq. Winston & Strawn LLP 2501 N. Harwood Street 17th Floor Dallas, Texas 75201 Re: Rent -A-Center, Inc. Preliminary Proxy Statement on Schedule 14A Filed April 11, 201 7 File No. 1-38047 Dear M r. Hughes : We have reviewed the filing above and have the following comment . After reviewing any amendment to the filing and the information you provide in response to this comment, we may have additional comments. All defined terms used in this letter have the same meaning as in the preliminary proxy statement unless otherwise indicated. We note that the prelimi nary proxy statement indicates that the record date for the Annual Meeting was April 10. It is our understanding that the record date has been changed to April 24. Please ensure the disclosure in the proxy statement is revised to reflect this new date. Please also tell us how the Company has complied with Exchange Act Rule 14a -13(a)(3) with respect to this solicitation. Include in your response the date that the Company conducted the inquiry required by Rule 14a -13(a)(1). It is our understanding that that the Company may have conducted such inquiry on April 20 notwithstanding a record date of April 24. * * * We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact me at (202) 551 -3444 with any questions. Sincerely , /s/ Perry J. Hindin Perry J. Hindin Special Counsel Office of Mergers and Acquisitions