SEC Comment Letter for UPBOUND GROUP, INC. (UPBD) (CIK 0000933036) (UPBD) — Apr 25, 2017
UPBOUND GROUP, INC. (UPBD) (CIK 0000933036)
Date: April 25, 2017 · CIK: 0000933036 · Accession: 0000000000-17-014335
AI Filing Summary & Sentiment
Reasoning
Letter
April 25, 2017 Thomas W. Hughes , Esq. Winston & Strawn LLP 2501 N. Harwood Street 17th Floor Dallas, Texas 75201
Re: Rent -A-Center, Inc. Revised Preliminary Proxy Statement on Schedule 14A Filed April 24, 201 7 File No. 1-38047
Dear M r. Hughes :
We are in receipt of your letter dated April 24 , 201 7 responding to our comment letter dated April 2 1, 2017 .
For the reasons conveyed to T odd Thorson on a telephone call earlier today, we are unable to agree with your conclusion that the required broker search was conducted more than 20 business days in advance of the April 24 record date for the annual meeting such that the Company complied with Exchange Act Rule 14a -13(a)(3). Please amend the Company’s proxy statement to acknowledge such non -compl iance. While the staff of the Division of Corporation Finance will not undertake any further examination of the Company’s non -compliance with this rule at this time, please note that the staff reserves the right to make further inquiry into this matter and make any recommendations it deems appropriate.
* * *
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) 5 51-3444 with any questions.
Sincerely,
/s/ Perry J. Hindin
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April 25, 2017 Thomas W. Hughes , Esq. Winston & Strawn LLP 2501 N. Harwood Street 17th Floor Dallas, Texas 75201 Re: Rent -A-Center, Inc. Revised Preliminary Proxy Statement on Schedule 14A Filed April 24, 201 7 File No. 1-38047 Dear M r. Hughes : We are in receipt of your letter dated April 24 , 201 7 responding to our comment letter dated April 2 1, 2017 . For the reasons conveyed to T odd Thorson on a telephone call earlier today, we are unable to agree with your conclusion that the required broker search was conducted more than 20 business days in advance of the April 24 record date for the annual meeting such that the Company complied with Exchange Act Rule 14a -13(a)(3). Please amend the Company’s proxy statement to acknowledge such non -compl iance. While the staff of the Division of Corporation Finance will not undertake any further examination of the Company’s non -compliance with this rule at this time, please note that the staff reserves the right to make further inquiry into this matter and make any recommendations it deems appropriate. * * * 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) 5 51-3444 with any questions. Sincerely, /s/ Perry J. Hindin Perry J. Hindin Special Counsel Office of Mergers and Acquisitions