SecProbe.io

Mail Stop 3720

September 2 1, 2016

Karl McDonne ll
Chief Executive Officer
Strayer Education , Inc.
2303 Dulles Station Boulevard
Herndon, Virginia 20171

Re:  Strayer Education , Inc.
Form 10 -K for Fiscal Year Ended December 31, 201 5
Filed February  19, 2016
Form 10 -Q for Fiscal Quarter  Ended June 30, 2016
Filed July 28, 2016
File No. 000 -21039

Dear Mr. McDonnell :

We have reviewed your filing s and have the following comment s.  Please comply with
the comment s in future filings.  Confirm in writing that you will do so and explain to us how you
intend to comply .

Please respond to th ese comment s within ten business days by providing the requested
information or advise us as soon as poss ible when you will respond.  If you do not believe our
comment s apply to your facts and circumstances, please tell us why in your response.

After reviewing  your response , we may have additional comments.

Form 10 -Q for Fiscal Quarter  Ended June 30, 2016

Management’s Discussion and Analysis  of Financial Condition and Results of Operations, page
22

Three Months Ended June 30, 2016 Compared to Three Months Ended June 30, 2015, page 27

1. Tell us how new student enrollments decreased by 7% but total enro llments increased.

Karl McDonnell
Strayer Education , Inc.
September 21 , 2016
Page 2

 Form 10 -K for the Fiscal Y ear ended December 31, 2015

Item 1. Business, page 1

Industry Background, page 2

2. We note your inclusion of statistics for college enrollments for 2014 and 2015.  You
should also provid e comparable statistics for for -profit -only colleges.

Regulation, page 10

Gainful Employment, page 17

3. We note that the new regulations went into effect on July 1, 2015 and that you have
provided the required information to the Department of Education.  Disclose your  current
annual income rate and discretionary income rate ratios.

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 of
1934 and all applicable 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 the disclosures they have made.

 In respo nding to our comment , 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 United States.

Karl McDonnell
Strayer Education , Inc.
September 21 , 2016
Page 3

You may contact Dean Suehiro , Senior Staff Accountant , at (202) 551-3384, or Robert
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have any questions regarding the
financial statements and related matters.  Please contact  Gregory Dundas, Attorney -Advisor, at
(202) 551 -3436,  or me at (202) 551 -3810 with any other questions.

Sincerely,

 /s/ Larry Spirgel

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications

cc: Daniel W. Jackson, CFO