SEC Comment Letter for Atlanticus Holdings Corp (ATLC, ATLCL, ATLCP, ATLCZ) (CIK 0001464343) (ATLC) — Nov 24, 2010
Atlanticus Holdings Corp (ATLC, ATLCL, ATLCP, ATLCZ) (CIK 0001464343)
Date: Nov. 24, 2010 · CIK: 0001464343 · Accession: 0000000000-10-070482
AI Filing Summary & Sentiment
File numbers found in text: 000-53717
Referenced dates: November 10, 2010
Letter
Re: CompuCredit Holdings Corporation Form 10-K for the Fiscal Year Ended December 31, 2009 Form 10-Q for the Quarterly Period Ended June 30, 2010 Form 10-Q for the Quarterly Period Ended September 30, 2010 File No. 000-53717 Dear Mr. Whitehead: We have reviewed your response letter da ted November 10, 2010 and have the following comments. 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 te n business days by providing the requested information, including a draft of your proposed disclosures to be made in future filings, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe future revisions are appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments, including the draft of your proposed disclosures, we may have additional comments. June 30, 2010 Form 10-Q
November 24, 2010 J. Paul Whitehead, III Chief Financial Officer CompuCredit Holdings Corporation Five Concourse Parkway, Suite 400 Atlanta, GA 30328
Investments in Previously Ch arged-Off Receivables, page 9
1. We note your response and revised disclosure related to comment 5b in your letter dated November 10, 2010. Please tell us why there is no remaining basis in balance transfer accounts at the time of card issu ance since it appear s that you make a payment to acquire these previously charged-off receivables.
J. Paul Whitehead, III CompuCredit Holdings Corporation November 24, 2010 Page 2
September 30, 2010 Form 10-Q
2. Please revise future filings to present the gain from the litigation se ttlement in a line item other than fees and related inco me on earning assets or tell us why you believe that is an appropriate presentation and provide supporting accounting guidance. It appears that a more appropriate presentation would be in other operating income. You may contact Michael Volley, Staff Acc ountant, at (202) 551- 3437, or me at (202) 551-3851 if you have questions. Sincerely,
Paul Cline Senior Accountant
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November 24, 2010
J. Paul Whitehead, III Chief Financial Officer
CompuCredit Holdings Corporation
Five Concourse Parkway, Suite 400 Atlanta, GA 30328
Re: CompuCredit Holdings Corporation
Form 10-K for the Fiscal Year Ended December 31, 2009 Form 10-Q for the Quarterly Period Ended June 30, 2010
Form 10-Q for the Quarterly Period Ended September 30, 2010
File No. 000-53717
Dear Mr. Whitehead:
We have reviewed your response letter da ted November 10, 2010 and have the following
comments. 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 te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested response. If you do not believe our comments
apply to your facts and circumstances or do not believe future revisions are appropriate, please
tell us why in your response.
After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
June 30, 2010 Form 10-Q
Investments in Previously Ch arged-Off Receivables, page 9
1. We note your response and revised disclosure related to comment 5b in your letter dated
November 10, 2010. Please tell us why there is no remaining basis in balance transfer
accounts at the time of card issu ance since it appear s that you make a payment to acquire
these previously charged-off receivables.
J. Paul Whitehead, III CompuCredit Holdings Corporation November 24, 2010 Page 2
September 30, 2010 Form 10-Q
2. Please revise future filings to present the gain from the litigation se ttlement in a line item
other than fees and related inco me on earning assets or tell us why you believe that is an
appropriate presentation and provide supporting accounting guidance. It appears that a more appropriate presentation would be in other operating income.
You may contact Michael Volley, Staff Acc ountant, at (202) 551- 3437, or me at (202)
551-3851 if you have questions.
Sincerely,
Paul Cline Senior Accountant