SecProbe.io

October 2 2, 2014

Via E -mail
Karl McDonnell
Chief Executive Officer
Strayer Education, Inc.
2303 Dulles Station Boulevard
Herndon, VA 20171

Re: Strayer Education, Inc.
Form 10-K for Fiscal  Year Ended  December 31, 201 3
Filed February 26 , 201 4
Response  dated October 8 , 2014
  File No. 000 -21039

Dear Mr. McDonnell :

We have  reviewed your response letter and have the following comment s.  As noted in
our letter dated September 3, 2014, 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.  Please comply with the following comments in future filings.  Confirm in writing
that you will do so and explain to us how you intend to comply.   In some of our comments, 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 request ed
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, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have  additional comments.

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

Critical Accounting Policies, Revenue Recognition, page 39

1. We note your response to comment 1.  Please disclose t he criteria for initial and
continuing eligibility in the Graduation Fund program.

Mr. Karl McDon nell
Strayer Education, Inc.
October 2 2, 2014
Page 2

 Financial Statements

Note 2. Significant  Accounting Policies

Revenue Recognition, page 52

2. Revise to disclose your refund policy for all services provided.

3. With respect to the education services provided by Strayer Education, please tell us if you
reassess collectability of tuition and fees after a student withdraws from a course, the
institution, or otherwise loses Title IV eligibility.   To help us better un derstand your
accounting policy, please provide us with the following information:
 tell us about the academic terms for online and campus -based institutions and if classes
are taken simultaneously or consecutively;
 tell us how you are notified when a stu dent withdraws from a course and/or the institution
and how you determine that a student has officially withdrawn from the institution;
 tell us how revenue is recognized for a particular course if a student withdraws from
the institution before and after  the institution’s refund period elapses, if any;
 tell us how revenue is recognized for a particular course if a student withdraws from
the institution before earning 100% of the Federal Student Aid funds he or she was
scheduled to receive during the perio d; and
 tell us about your historical collections experience with students who become
responsible for tuition and related fees due to withdrawal or loss of financial aid
eligibility.

Note 5. Restricted Cash, page 52

4. Please tell us and disclose the amounts  of any funds restricted for return of Title IV funds
to the Department of Education.  If not considered restricted funds, plea se advise us of
the rationale.

You may contact Robert Shapiro , Staff Accountant, at (202) 551 -3273 or Joseph M.
Kempf , Senior Staff Accountant,  at (202) 551 -3352  if you have questions regarding comments
on the financial statements and related matters.  Please contact me at (202) 551 -3810 with any
other questions.

Sincerely,

/s/ Carlos Pacho for

Larry Spir gel
Assistant Director